Scottish Ministers have made the Revenue Scotland and Tax Powers Act (Interest on Unpaid Tax and Interest Rates in General) Amendment Regulations 2026 (SSI 2026/17), clarifying how interest applies to unpaid Scottish Aggregates Tax. The instrument was made on 20 January 2026, laid before the Scottish Parliament on 22 January 2026, and will commence on 1 April 2026.
The Regulations amend regulation 4(1) of the 2015 Interest Regulations by inserting a new row for Scottish Aggregates Tax. Where a return is made under regulations made under section 23 of the Aggregates Tax and Devolved Taxes Administration (Scotland) Act 2024, the “relevant date” from which interest on unpaid tax runs will be the filing date for that return. (legislation.gov.uk)
For these purposes, “filing date” has the meaning in section 82 of the Revenue Scotland and Tax Powers Act 2014: the date by which a return is required to be made under an enactment. (legislation.gov.uk)
Under section 217 of the 2014 Act, interest is payable on unpaid tax from the relevant date until payment, with the rate set under section 220 and the 2015 Regulations. Revenue Scotland guidance confirms late payment interest is calculated at the Bank of England base rate plus 2.5% and applied as simple interest. The posted late‑payment rate from 24 December 2025 is 6.25%. (legislation.gov.uk)
The change aligns with the go‑live of the Scottish Aggregates Tax on 1 April 2026. Revenue Scotland indicates enrolment opens in early 2026, with guidance to follow ahead of implementation. (revenue.scot)
UK legislation will disapply the UK Aggregates Levy in Scotland from 1 April 2026 and provide for cross‑border credits, avoiding double charging when aggregate moves between jurisdictions. HM Treasury has set out the intended changes. (gov.uk)
The approach is consistent with existing devolved taxes. The 2015 Interest Regulations already treat Scottish Landfill Tax returns as accruing interest from the filing date, while Land and Buildings Transaction Tax has specified dates for different scenarios. The SAT amendment extends that structure to a third devolved tax. (legislation.gov.uk)
Operationally, quarry operators, importers and other SAT taxpayers should assume that, once accounting periods and payment schedules are confirmed in secondary legislation, interest will accrue from the filing date if payment is late. Draft administration regulations and recent guidance updates indicate systems and penalties are being prepared for April 2026. (gov.scot)
The Regulations are signed on behalf of the Scottish Ministers by the Minister for Public Finance, Ivan McKee, at St Andrew’s House, Edinburgh. His portfolio includes oversight of Revenue Scotland. (gov.scot)