The Meccan Revelations: Page 556 from Volume One

From this section, the land of the tax, if it is transferred to the Muslims,

It is the land that was in the hands of the people of Dhimma. Does it have a tenth in it along with the tax or not? Whoever says that it has a tenth in it, I mean zakat, and whoever says that it does not have a tenth in it, then know that the zakat is either a right. The land or the right of love. If it is the right of land, zakat is not obligatory because two rights are not combined in it, which is the tenth and the tax. If it is the right of love, then the tax is the right of the land and the tenth is the right of love. The dispute over selling the land of the tax is known to scholars.