Scottish Ministers have made an amendment to the 2015 Involved Third Party Order so that Scottish Aggregates Tax (SAT) is treated as a “relevant devolved tax” for the inspection power in section 142 of the Revenue Scotland and Tax Powers Act 2014. The change applies from 1 April 2026, aligning investigatory powers with the introduction of SAT. (legislation.gov.uk)
The Order specifies that any person involved, in any capacity, with the commercial exploitation of taxable aggregate is an “involved third party” for SAT purposes. This brings quarry operators and others connected to exploitation within scope of section 142 when officers are checking the position of any person in relation to SAT. (gov.scot)
“Commercial exploitation” follows the statutory definition in section 7 of the Aggregates Tax and Devolved Taxes Administration (Scotland) Act 2024. Aggregate is commercially exploited when, in the course of business, it is removed from its originating or relevant site, becomes the subject of an agreement to supply, is used for construction, or is mixed (other than in permitted circumstances) with another substance. (legislation.gov.uk)
Only aggregate that is “taxable aggregate” falls within scope. Under section 5 of the 2024 Act, aggregate is taxable on any occasion it is commercially exploited, except to the extent it is exempt under section 6. (legislation.gov.uk)
The Order also defines “relevant documents” as any documents relating to the commercial exploitation of taxable aggregate. In practice, this can cover contracts, invoices, weighbridge tickets, delivery notes, production and stock records, and procurement files, including digital records preserved under RSTPA rules. (gov.scot)
From 1 April 2026, Revenue Scotland may enter business premises of an involved third party to inspect the premises, business assets on the premises and relevant documents where there is reason to believe the inspection is reasonably required to check any person’s position regarding a relevant devolved tax. SAT is now such a tax for these purposes. (legislation.gov.uk)
Inspections must follow the statutory safeguards in section 143 RSTPA 2014. They occur at an agreed time, or at any reasonable time with at least seven days’ notice, or without prior notice where giving notice would seriously prejudice assessment or collection; a written notice must be provided in all cases covered by the statute. (legislation.gov.uk)
There are clear limits. The power does not extend to any part of premises used solely as a dwelling. Revenue Scotland guidance confirms additional care where a business is run from a home, with alternatives normally sought unless the taxpayer requests otherwise. (legislation.gov.uk)
The supply chain likely to be touched by these changes includes quarry operators, importers, merchants, contractors and public bodies procuring aggregate in Scotland. Revenue Scotland’s published material indicates all such actors may be affected when aggregate is commercially exploited in Scotland. (revenue.scot)
Compliance preparation now centres on record‑keeping and site access protocols. Record‑keeping requirements under RSTPA-updated in late 2025-expect businesses to preserve supporting documents and be able to produce them in a usable form. Organisations should identify a responsible contact for inspections and ensure records linked to exploitation are promptly retrievable. (legislation.gov.uk)
Operational timing is consistent with the wider transfer from the UK Aggregates Levy to SAT on 1 April 2026. UK Government material confirms UK‑level adjustments to the Levy from that date for cross‑border supplies, while the Scottish Government states SAT will start on that date and be administered by Revenue Scotland. (gov.uk)
For context, the 2015 Involved Third Party Order originally addressed Scottish Landfill Tax. The 2026 amendment adds a dedicated article for SAT, ensuring the same investigatory architecture applies to the aggregates regime as it goes live. (revenue.scot)