My idea would be that Grey Users only get to use the Hide-Tag where you have to reply to a topic to get the download link.
Upgraded users on the other hand should get an Upgraded-Hide Tag.
They then have the option to give grey users a shortlink to the download through the hide tag which lets them make money by uploading HQ stuff and supporting Nulled in the process.
The upgraded hide tag is only visible for upgraded users and contains a non-shortlink download link. this is to reward the users that paid for upgraded.
Non upgraded users can not see the upgraded hide tag.
Upgraded users can see the hide and upgraded hide tag to have an option to support the uploader.
Hope i wrote that as clearly as possible.