(concurring in result).
I concur in result. As the trial court held, the conclusion that this is not an “in lieu of tax” but rather an “additional original registration tax” is borne out by the plain, unambiguous language of the statute. See St. Paul Ramsey Medical Ctr. v. Pennington County., 402 N.W.2d 340, 344 (S.D.1987) (“One of the primary rules of statutory construction is to give words and phrases their plain meaning and effect. This court has ruled that we assume statutes ‘mean what they say and that the legislators have said what they meant.’ When the language of a statute is clear, certain, and unambiguous, there is no occasion for construction, and this court’s only function is to declare the meaning as clearly expressed in the statute.” (Citations omitted.) (Emphasis added.)).
The statutory language of SDCL 50-11-19 imposes “an additional original registration tax of four percent” which “shall be paid[.]” The additional language contained therein does not establish an exemption from the payment of this tax for Sioux Valley Hospital. Rather, the payment of the tax entitles Sioux Valley Hospital to an exemption from the payment of certain other taxes levied by the State, whether or not Sioux Valley Hospital is otherwise liable for those taxes. SDCL 50-11-19.
*337The plain language of this statute imposes a four percent additional original registration tax on all aircraft purchases. And as SDCL 50-11-19 further provides: “After this ... tax has once been paid ... none of the above-mentioned taxes shall thereafter be assessed or paid[.]” (Emphasis added.) Therefore, only upon payment, do the exemptions even come into play.*
Additionally, as noted by the trial court, this "conclusion is also supported by the fact that the exemption guaranteed for charitable institutions in [SDCL] 10-45-14 specifically says that the exemption is only applicable to taxes imposed by Chapter 10-45.” See SDCL 10-45-14 (“There are specifically exempted from the provisions of this chapter and from the computation of the amount of tax imposed by it, the gross receipts from sales of -tangible personal property ... to and for use by ... nonprofit, charitable hospitals[.]”).