Shannon Mills

This Practice Note outlines what the aggregates levy is, who is liable to pay it, what the meaning of a taxable aggregate is, what is exempt or non-taxable, what the rate of the aggregates levy is and whether reliefs apply. It also looks at when an aggregate is exploited, what registration requirements there are, how to account for the aggregates levy, record keeping requirements and interaction with landfill tax. Aggregates levy issues may arise when undertaking due diligence for the acquisition of a mining or quarrying business, or when advising a client on environmental tax obligations.

What is the Scottish Aggregates Tax?The Aggregates Tax and Devolved Taxes Administration (Scotland) Act 2024 (ATDTA(S)A 2024) brings into force the Scottish Aggregates Tax (SAT) in Scotland from 1 April 2026 replacing the UK Aggregates Levy (UKAL) for the taxation of aggregate in Scotland. Until that date, the UKAL continued to apply in Scotland. Similar to the UKAL, the SAT is an environmental tax. It is administered by Revenue Scotland on the commercial exploitation of aggregates in Scotland. The Scotland Act 2016 provided the Scottish Parliament with the power to introduce a devolved replacement for the UKAL.The SAT has been designed as a replacement for the UKAL in Scotland with the explicit aim of minimizing complexity and preventing businesses which had not previously been within scope of Aggregates Levy from becoming liable to the tax.The SAT also ensures that double taxation is avoided on aggregate which has been supplied cross-border by middlemen in a supply chain, such as builders merchants, by ensuring that the aggregate which