Court qualifies municipal underground soil usage fee as a tax due to its reciprocal nature.

The Supreme Administrative Court unanimously allowed the appeal, ruling that the municipal charge for underground soil usage constitutes a tax rather than a fee. The municipality argued the charge was a fee for specific infrastructure installation, while the appellant contended its reciprocal nature and destination for individualized subsurface use defined it as a tax. The court established that the signalagmatic nature of the payment, intended to cover individualized subsurface utilization, legally characterizes it as a tax.