Royalty as compensation: payments for the right to exploit state resources are treated as economic rent, not a tax.

Royalty denotes compensation for rights and privileges to exploit resources or proprietary rights, historically rooted in jura regalia and payments for working mines. In tax terms, royalties are characterised as consideration for extraction or use of State-owned resources-reflecting the economic concept of economic rent-rather than as a tax aimed at raising general revenue, and are therefore treated as payments linked to proprietary rights and usage.

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