Royalty payable for a State Government grant of mineral...

Royalty payable for a State Government grant of mineral extraction rights under a Short-Term Permit is contractual consideration for licensing services involving the right to use minerals, rather than a tax. The permit holder, as recipient of a Government-to-business supply, must discharge GST under reverse charge at 18%. The shorter duration and restricted area of a Short-Term Permit do not change the nature of the supply where the grantor, extraction rights and royalty basis correspond to those for quarry and mining leases. Short-Term Permit holders therefore receive the same reverse-charge GST treatment as quarry and mining lease holders.