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Maliyat Journal, No. 11 - Spring 1996

 

 

IN THE NAME OF GOD

 

FROM THE PRESIDENT

Tax compliance is regarded everywhere as a great ideal and standard of perfection for the tax administration. Those responsible for managing the taxation affairs have always been endeavoring to elevate the degree to which taxpayers respond to their statutory duties under the tax laws.

The subject of tax compliance is of several dimensions, and a thorough study is needed to comprehend its various aspects. One thing is certain, however, and it is the simple fact that the tax compliance is to be sought from the taxpayer. So, the psychological conditions of taxpayers and their probable reactions are to be taken into account as most important considerations.

What factors, then, may potentially affect the attitude of taxpayers? Several points might be raised in response to this question. Among them one can undoubtedly refer to the behavior of tax organization in relation to taxpayers. This is a determinant element that can provide critical effects on accomplishments and acquirements of tax organization.

Such a vital and important matter must be carefully organized and kept under a viable order. This requires, first and foremost, designating clear and realistic goals to the behavior of tax authorities.

Otherwise such behavior would deviate to directions contrary to the objectives of tax administration and might, most probably, be subjected to personal considerations.

It is the business of policy makers to decide upon, and determine the objectives of taxation system, including the manner of action of tax organization. Existence of clear, and properly enforceable, directives in this regard would prevent the officials to stray from reasonable behavioral norms.

Some directives issued recently by tax administration contain instructions that may be interpreted as guidance towards a lawful and objective way of acting.

A ministerial circular, for instance, deals with the subject of taxpayers' appeal. Taxpayers dissatisfied with tax assessment may appeal the decision to a body called the Board of Settlement of Tax Disputes. The statement of appeal must be submitted in writing and be signed by the appellant.

Most of those Boards have been so far rejecting the appeals on basis of sole excuse that they were not signed, or signed improperly. The ministerial circular disapproves that procedure and instructs the Boards to consider the appeals valid, and to review them, even if they are somehow defective as far as the signature is concerned. Only when there are sufficient grounds to believe that the appeals are unreal and forged, they must, according to the ministerial circular, be rejected accordingly.

The instruction contained in the circular takes into account the real intention of the law. To grant the right of appeal to taxpayers is a principle recognized throughout the world. The same has been adopted by the Iranian tax regulations. This basic and significant rule of justice must not be rejected on basis of a weak excuse such as defects in signing.

Some other directives of the same character are also being issued by the Finance Ministry, most of them emphasizing the need to observe the spirit, instead of appearance, of the law. Tax officials are instructed to pay attention to substance of regulations and realities of cases, and to avoid resorting to superficialities of law and outward aspects of cases involved. It might be alleged that adhering to such attitude would weaken the ability of tax organization in assessment and collection of taxes, and thereby the fall of revenue would occur.

This argument does not seem to be strong enough. Demanding payment of taxes on basis of weak and superficial grounds would, on the contrary, induce tax evasion. People would lose their confidence on impartiality and objectiveness of tax organization; a situation that might seriously impair the spirit of compliance among various groups of taxpayers.

 

Dr. Aliakbar Arabmazar

 

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NATURE OF "ADDITIONAL 10%" ENVISAGED UNDER

 

THE ARTICLES 211 AND 215 OF THE DIRECT TAXATION ACT

 

By Dr. Mohammad Tavakkol

 

Chapter ten of the Book four of the Direct Taxation Act (DTA) defines the ways and means of tax recovery by the Finance Department: A notice shall be served on the taxpayer whose liability is determined in a final mode. If he would fail to pay such finalized tax within 10 days from the date of notification, then a second notice called "the sheet of execution" (meaning approximately the "writ of execution") is to be notified to him. The writ of execution would demand the taxpayer to pay the sum of finalized tax plus the applicable fine. The taxpayer must pay, or arrange for payment of, his liability within one month from the date he receives the writ of execution. In case of failing, his property, real or personal, to the amount of his tax "liability" plus 10% of the same will be seized.

The term seizure under Article 211, DTA means taking into the custody of law the property of a liable person, in order that such property may be sold, by authority and due course of law, to settle his liability.

The phrase "taxpayer's liability" comprises - according to the wording of Article 211 - the tax assessed plus the applicable fines. So the seizure of property would take effect up to an amount covering not only the total liability of delinquent taxpayer, but it also would include an extra amount of 10% of the "liability": assessed tax + applicable fines + 10% of the first and second items.

The aim of the present article is to analyze the third element of the above equation, and to reach a conclusion about its implications. What is the essence of this extra amount of 10%? Three answers are conceivable to this question:

1. It is a guarantee for insuring the recovery of what is called "the cost of execution",

2. It has the nature of a fine, and constitutes an additional penalty imposed on delinquent taxpayer, or

 3. It is a substitute for the interest accruable to the period during which the tax was in default.

There is some evidence, as we will see later, to support the first and second assumptions, but no ground does exist to attest the reliability of the third supposition. It is worth mentioning, in addition, that demanding interest for late payment of money is considered by religious authorities to be a kind of usury, and therefore is prohibited under the Islamic Canon Law (fiqh). So we have to leave it and concentrate on the first and second assumptions.

The first assumption is based on the fact that the execution process requires some expenditure, which should be naturally born by those who are responsible for them. Where a taxpayer fails to settle his liability on time, nobody except him is to be considered responsible for execution operations, and he personally has to bear the cost.

But those operations would not usually take place at once, and they need time to be carried out. The exact amount of execution cost can not be determined at starting; therefore a provisional amount is expedient to receive from the taxpayer to guarantee the final recovery of the cost.

Such is the meaning of the first assumption. The additional 10% is a means for guaranteeing the payment of the execution cost. Natural result of this assumption is to consider that additional 10% an advance and provisional receiving. If it is an advance against the execution expenditures, then the balance, if any, should be adjusted and settled when the execution operations come to conclusion.

We would call this first assumption as the "assumption of guarantee".

The second assumption, which we would call "assumption of fine", implies that the said additional 10% is a kind of penalty imposed on the failing taxpayer. The total liability of the taxpayer, according to this assumption, equals to: assessed tax + applicable fine + additional fine + execution cost.

 

ASSUMPTION OF GUARANTEE

Several indications and evidence might be presented in favor of this particular assumption. Those include:

1. Article 211, DTA, states clearly that the seizure of taxpayer's property would take place to an amount equal to: tax + fine + additional 10%. No reference is made by the article to the execution cost, while the cost of execution should be certainly recovered from the delinquent taxpayer. So we can infer easily that the additional 10% referred to in this article, is undoubtedly connected to the element of execution cost. It can not be anything except a guarantee against the expenditures of execution. Without such assumption it would become extremely difficult to justify the absence of execution cost among the components enumerated by Article 211.

2. Note 1 to Article 212, DTA declares the following rule:

"In cases where the value of the property to be seized is more than the "tax liability", and it is not susceptible to division, then the whole property shall be sold and the balance of price shall be refunded to the taxpayer, unless he would offer another indisputable property of the value equal to the said tax liability."

The term "tax liability" in this Note refers to the assessed tax plus applicable fine. It does not include the extra 10%. This is a meaning given to the phrase "tax liability" by Article 211, which explicitly defines it and separates it from the new element of additional 10%.

The Note 1 to Article 212 does not pay attention to that element of extra 10%, since it is not a component of tax liability. It is a guarantee for the cost of execution and not a liability by itself.

3. Let us turn to Article 215 of the Direct Taxation Act. This article pertains to the process of property seizure. It reads as follows:

"As far as the real property is concerned, if after two times publication of auction advertisements...no purchasers were found, the Ministry of Economy and Finance may transfer to its ownership a part of the seized property, the value of which...is equal to the total tax liability of the taxpayer plus the applicable cost..."

As we can see from the wording of Article 215, no mention is being made here of the said extra 10%. The "applicable cost" is substituted for that component. The situation is reversed in Article 211, where no reference is made to cost of execution, and the additional 10% is substituted for it. Once more we sum up the content of these two articles in the following formulae:

Article 211: assessed tax + applicable fine + extra 10%

Article 215: assessed tax + applicable fine + applicable expenditures

Since both articles are from the same chapter of DTA, and both are pertaining to one and the same subject, they can not be interpreted, except in a way to convey equal understanding and compatible meaning. This obvious reasoning would lead us to conclude that the element of extra 10% is completely connected to the applicable costs, namely the cost of execution. In other words, it is a guarantee for recovery of execution cost.

 

ASSUMPTION OF FINE

As it was explained above, there are at least three indications in favor of the assumption of guarantee. As far as the assumption of fine is concerned, however, it is only the Note 1 to Article 215 that might convey such understanding. This Note is pertaining to a case where no purchaser is found for the seized real property, and the Finance Ministry is going to own it or to transfer it to other purchaser. If before transferring of ownership, "the taxpayer would volunteer to pay his liability, and then the Ministry of Economy and Finance shall restore the property to him upon receipt of taxpayer's liability plus 10% thereof and the applicable costs."

This article, if looked at by itself and separated from the rest of the relevant provisions of the law, might be understood to mean that the amount receivable, in such cases, from the taxpayer comprises the following items: tax + fine + cost + 10%

This result is consistent with the assumption of fine. The additional 10% is a secondary fine that the taxpayer must pay.

 

INCONSISTENCIES

The formula so deducted from the appearance of Note 1 to Article 215 is in contradiction with other relevant provisions of the law. None of those regulations combines the execution cost and extra 10%. They either refer to the cost exclusively, or to the additional 10% solely. Therefore, by adhering to the assumption of fine, we have to confine our assumption to a particular case. That is where the Ministry is on verge of transferring the seized real property, and the taxpayer volunteers to pay his liability.

Even in this isolated case, the assumption of fine would involve logical inconsistencies. Firstly, it implies the punishment of a taxpayer who volunteers at this stage to comply with his legal duty. This punishment would not be applicable to the same taxpayer if he would continue to ignore his duties even at this last stage.

Secondly, the extra punishment so deducted from Note 1 to Article 215, would apply to the owners of real properties. In case of personal properties such additional punishment can not be applied!

Thirdly, Note 1 to Article 215 is in contradiction with Note 1 to Article 212 as well. The latter provides explicitly that where the value of property seized is more than the taxpayer's liability, and the property is indivisible, then the entire property shall be sold and the balance of price shall be refunded to the taxpayer "unless he offers another indisputable property, the value of which is equal to the said tax liability."

The case foreseen under the Note 1 to Article 212 may overlap the case of Note 1 to Article 215. A taxpayer whose real property is seized, and the Finance Ministry is going to sell it, might be subject to both Notes. One might say that Note 1 to Article 212 pertains to a case where the value of property exceeds the liability, while the Note 1 to Article 215 relates to a situation where such difference of value does not exist. Such argument would leave us with an illogical and very tasteless result.

 

THE SUPREME COUNCIL OF TAXATION

The subject analyzed above was referred to the Supreme Council of Taxation (SCT) for reviewing. The SCT reviewed the matter and concluded that the seizure of property, as far as the additional 10% is concerned, does not mean necessarily that it is a liability for the taxpayer. The verdict of SCT up to this point is correct and admirable. The SCT, however, failed to solve the discrepancy of Note 1 to Article 215, and receded by stating that the said Note is to be confined to the specific case foreseen by it. Thus, the SCT accepts all inconsistencies and illogical consequences associated with this kind of literal interpretation of the law.

 

CONCLUSION

Interpretation of law is not advisable to be confined to strict wording of its provisions. The logical method of construing is, in most cases, much more expedient way of interpretation. An article, or a particular note to it, is not an enclave inside the code of law. It is a part of the whole and can not be construed except by referring to the overall logic of the law. A section or chapter of the law containing that specific article or note is the minimum environment that should be taken into account.

If a particular article or note conveys some illogical meaning, the discrepancy must be resolved by resorting to the said logical interpretation. Even the historical method of interpretation might sometimes be of great value. It means to refer to precedence of drafting and legislation of law, to discover the real intent, behind the appearance, of the law.

The inconsistency associated with literal construing of Note 1 to Article 215 of the Direct Taxation Act can, and must, be solved through such appropriate methods of interpretation.

 

 

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Tax News

 

BY-LAW ON SELECTION AND QUALIFICATION OF OFFICIAL ACCOUNTANTS

A law was enacted two years ago "concerning the Use of Professional Services of Qualified Accountants". It was stipulated under the law that the detailed regulations about qualifications of official accountants and other related matters will be enacted in a later stage (see Maliyat, No. 3. The by-law referred to above has been recently adopted by the Council of Ministers as complementary regulations to the said law. It provides for establishment of a special body called:

"The Board Responsible for determining the Qualifications of Official Accountants". Members of the Board will be appointed by the Minister of Economy and Finance.

The applicants for the profession of official accountancy have to pass an examination to be arranged and supervised by the said Board.

The Board is responsible for controlling the activities of official accountants. After each term of five years, the Board has to reconsider and reconfirm the competency and qualifications of official accountants. It may reject to confirm, in which case would decide upon temporary or permanent deprivation of the applicant from practicing this profession. The official accountants should possess the following qualifications:

- having Iranian nationality and being allegiant to the constitution of this country.

- Not being convicted of a crime.

- having a good reputation for observing religious and social duties, and not being addicted to narcotic drugs.

- having received BA or higher degrees in the field of accountancy or similar subjects.

- Having worked for a minimum period of 6 years as auditor after receiving his/her academic degree.

- having passed the examination to be arranged by the Board.

The official accountants who are employed by public or private institutions, or are self employed, are prohibited to practice the profession of official accountancy in addition to their principal job. The permission granted to such persons will be withdrawn, and a new permit will be issued, qualifying them as "engaged accountants".

 

TAX ON TRANSFER OF GOODWILL

Transfer of goodwill is subject to taxation under the amended Article 95 of the Direct Taxation Act. Progressive rates of tax are provided by the tax law, which increase depending on the slices of the price of transaction. The value of goodwill is to be determined on the basis of what is called "transactional value".

The term transactional value might not convey reality of the case. More exactly speaking it can be called taxation value of transaction, since it is determined for tax purposes only.

The transactional (or taxation) value of goodwill for properties located in different areas is to be drawn up by the Ministry of Economy and Finance. Before such valuation is effected, the price actually received by the transferor of the goodwill will constitute the basis of taxation. A number of taxpayers try to escape the tax, and to that end underreport, or even deny, the receipt of what has actually paid to them.

To circumvent this type of evasion, the tax officials resort usually to estimation of taxable amount by reference to market value of the relevant goodwill.

This procedure might cause unfairness if it is applied universally and with no exception. There are people who lease a property against a high rental, and then would either receive a moderate key money, or no such consideration at all.

A circular issued recently by the Finance Ministry examines this subject and states that taxation should take effect when reliable evidence would indicate that taxpayer has received certain amount of money as consideration for transfer of goodwill. If such evidence is absent, then no ground does exist to justify taxation, and officials must refrain applying it to relevant cases.

 

TAXPAYER'S SIGNATURE

The Direct Taxation Act accords the Board of Settlement of Tax Disputes the authority to review and decide upon tax disputes (Article 244). Any taxpayer dissatisfied with tax assessment may appeal the same to that Board. The statement of appeal must be submitted in writing and it should be signed by the appellant. Most of BSTDs have been so far rejecting the appeals if they were not signed, or signed improperly.

The Ministry of Economy and Finance has issued a circular dealing with the same subject. It disapproves the procedure followed by BSTDs, and instructs them to consider the appeals valid and to review them, even if they are not properly signed. Only when there are sufficient grounds to believe that the appeal is unreal or forged, or the taxpayer is not aware of it, then the BSTDs must reject it accordingly.

 

MUNICIPAL SURCHARGE

The Law of the First National Development Plan had provided for a special surcharge in favor of municipalities around the country. The rate of the surcharge was 3% of taxable income of certain categories of taxpayers. The responsibility for collection of the surcharge was entrusted to tax departments, and they had to apply it in addition to normal income tax of the taxpayers.

The aforesaid law was confined to the duration of the first development plan, which expired at the end of the Iranian solar year of 1372 (March 20, 1994). Therefore the finance departments were instructed last year to discontinue applying the surcharge. But recently they were instructed again - under a new ministerial circular - to collect the same surcharge from the relevant taxpayers. 

 

CHAMBERS OF COMMERCE, INDUSTRIES, AND MINES

The Law concerning the Expenditures of the Chambers of Commerce, Industries and Mines was enacted on November 2, 1993. It provides that 0.03% of the taxable income of all merchants (those holding trade cards) is to be collected and remitted to the Treasury. Then the money would be put at the disposal of the said chambers. Tax departments are responsible for collection of this special item, when collecting the income tax of the relevant taxpayers. A new circular of the Finance Ministry reaffirms the contents of the said law, and invites tax officials to pay due attention to exact enforcement of the same.

 

EX OFFICIO ASSESSMENT

The cases of ex officio tax assessment are mentioned under the Article 97 of the Direct Taxation Act (DTA). Section 3 of this article pertains to a case where the books and documents of the taxpayer are deemed to be inadequate for verifying, or where the books are found to be kept not in accordance with legal standards. The tax assessor is authorized, in such cases, to make an assessment according to the best of his judgment. The assessor must inform the taxpayer, and should refer the case to a board of 3 auditors, designated by the Ministry of Finance and Economy. The taxpayer may defend his case before the same board. The time limit for tax assessor, on the other hand, is 14 months after the deadline provided for filing the tax return (Note to Article 97 and Article 156, DTA). If the tax assessor would fail to assess the taxes due within one month after expiration of the aforesaid time limit, he would lose his right of ex officio assessment, and the tax return submitted by the taxpayer shall be considered finalized. A ministerial circular addressed to all tax officials, orders them to pay due attention to the aforesaid time limit. The circular discusses in particular the subject of referring the case to the Board of Editors. It points out that such referring can take place only after the ex officio assessment by the tax assessor. If an assessor fails to assess the tax within the prescribed time limit, then the right of ex officio assessment will be lost, and no room will be left for directing the case to the Board of Auditors.

 

REVENUES ALLOCATED TO THE MINISTRY OF EDUCATION

According to a decree adopted by the Council of Ministers, two kinds of revenue have been established to be collected and paid to the Ministry of Education. They are as follows:

1. The factories, companies, and entities engaged in the business of production, exchange, or distribution of certain goods and services, are obliged to collect from the purchasers an amount equal to 2% of the selling price. The kind of goods and services subject to this levy is to be determined from time to time by the government. At this stage, steel, cars, copper, aluminum, petrochemical products, and some other goods are declared to be subject to the aforesaid sale duty. The money so collected is to be transferred quarterly to the banking accounts declared by the taxation authorities. Non compliance with the duties of collection and transfer of these charges shall be subject to the same regulations and sanctions provided in respect of ordinary taxes.

B. The second type of revenue must be collected by the municipalities in each district. Any person willing to receive permission for construction or renovation of building or demarcation and separation of land, must pay this specific revenue to the relevant banking account and submit the receipt to the local municipality, otherwise the permissions shall not be granted to them. The amount of this second type of revenue is to be determined by a committee composed in each province of Provincial Governor, Director General of Economic Affairs and Finance, Director General of Education Department, Director General of Housing and Town Planning, and Director General of Innovation of Schools.

 

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ABSTRACT OF PERSIAN ARTICLES

 

EDITORIAL

The editorial in this issue examines the subject of tax officials' behavior in relation to taxpayers. It has been considered an important factor that may have critical effects on accomplishments and acquirements of the tax organization. The English editorial is also dealing with the same subject.

 

SALARY TAX OF EMBASSIES' LOCAL PERSONNEL

According to the press, the US Embassy in England used to underreport the salaries of its employees. This behavior lasted for more than thirty years, before the English tax authorities discovered it and protested Americans together with a claim of 3 million Pounds for unpaid taxes, as well as the accrued interest and fines.

The article examines the same subject in Iran and concludes that the situation is much worse in this country, since in most cases no taxes are ever paid by the embassies in relation to their taxable personnel, who are mostly local Iranians, and sometimes foreign ordinary employees. The salaries paid to these local personnel are usually very high in comparison to the Iranians with same qualifications, who work for the internal entities and organizations.

A part of the salary of embassies' local personnel is paid in hard currencies, which is usually transferred to their accounts in foreign banks. Therefore the amount of taxes so evaded from, is proportionately very considerable. The author considers this situation contrary to law and principles of justice, and suggests that an appropriate action be taken by the authorities. One way, according to the author, is to ask the Ministry of Foreign Affairs to contact the embassies and want them to pay the accrued salary taxes of their local employees. In case the Ministry is reluctant to do so, could at least demand the embassies to provide a list of such employees and amounts paid to them in national and foreign currencies.

 

COMMENT ON TRANSPORTATION AGREEMENTS CONCLUDED BETWEEN IRAN AND OTHER COUNTRIES

The Iranian government has recently become very active in the sphere of such kind of international relations. Three agreement of this kind, namely those concluded with Germany, Armenia and Ukraine, are chosen and commented upon by the author. Several cases of discrepancies between these three agreements, as well as inside each of them, are discovered and criticized in the article. The parts of each agreement dealing with taxes and customs duties are analyzed in more detail, and discrepancies are found here as well. The author suggests that such taxation provisions of international agreements must in the future be submitted to the Finance Ministry for specialized deliberations, before the steps being taken towards the final conclusion of the agreements.

 

CAPITAL GAINS REALIZED FROM INCREASE IN THE VALUE OF COMPANIES SHARES AND STOCKS

One important source of capital gains is the disposal of shares or stocks of the companies, which values have been tremendously increased during the recent years.

Taxation of this source of income was ignored by the authorities for a long time. It is only a few years that the government has paid attention to imposition of tax on it. The rates and base of taxation were changed few times, and some unequal treatments were evolved during this short period of time. That has led to a situation where the idea of canceling this taxation has recently put forward by some authorities. The article examines all these subjects and presents some proposals for rectifying this situation without the need to cancel these newly imposed taxes.

 

COMPARATIVE STUDIES: CORPORATE TAX RATES

This series of articles, the aim of which is to examine corporate income tax in different categories of countries, is continued in this issue of the journal as well. Countries reviewed are Venezuela and Nigeria. These countries are both members of OPEC (Organization of Petroleum Exporting Countries) and both derive most of their income from exportation of oil. At the meantime, both are considered developing countries. The same qualifications are true in respect of our country as well. The survey reveals that the corporate tax rates are moderate in Venezuela and considerably high in Nigeria.

 

HISTORY OF TAXATION

The era of Achemenid Empire (sixth to fourth centuries BC) is examined in the article. The cuneiform inscriptions of Achemenid kings, as well as the writings of contemporary Greek historiographers are reviewed. The tribute used to be the most significant kind of taxes in that time. A list of tributes delivered to the treasury by each state of Achemenid vast empire is presented in the article.

 

SELECTION AND TRAINING OF TAX OFFICIALS IN FEDERAL REPUBLIC OF GERMANY

This is a translation of the paper presented by the General Director of Revenue of Germany to the twenty first General Assembly of the

Inter-American Center for Tax Administration (CIAT). The original title of the paper had been: "Staff Development in Tax Administration". Three categories of personnel are described, and their qualifications, education, and training are examined in the article.

 

A FINANCIAL DOCUMENT FROM THE ERA OF QAJAR DYNASTY

This is a report from the head of the Finance Department of Kermanshah Province, addressed to the Minister of Finance. The document is dated May 28, 1917, when the First World War was going on and many areas of the country were under occupation of Russian, British, and Ottoman troops. The head of the Kermanshah Finance Department reports that the Russian army demanded the purchase of all wheat and barley which was going to be delivered to the Finance Office, as tax.

 

LETTERS AND INQUIRIES OF READERS

The opinions of two readers regarding certain verdicts of the Supreme Council of Taxation are presented and commented on in this issue of the journal. The inquiries of our readers related to different tax matters are also answered by tax experts.

 

IRANIAN MINISTERS OF FINANCE IN TWENTIETH CENTURY

Iranian constitutional reform took place at the first decade of the present twentieth century, and now we are approaching the end of the century. The modern administration, including taxation system, was also established from the same time onwards. This journal begun to print the pictures of the ministers of finance from the date of establishment of constitutional system. Readers can see them on second and third pages of the cover of the present issue, and also on the second pages of issues 8 and 9 of the journal. The names and dates of appointment of the ministers are also printed inside the journal.

 

REGULATIONS AND RULINGS

The texts of latest laws, regulations, decrees, and opinions of the Supreme Council of Taxation are reported in the Persian section of the Journal. A summary of the same is provided in the English section under the heading "Tax News."

 

SELECTED CASES BEFORE THE TRIBUNALS

This section is devoted to the international arena. Cases are selected so that to be of interest to the Iranian readership.

 

Book Review

Authors and publishers are invited to submit one copy of their books and publications to the Editor for review. In each issue we will review their works and introduce them in both English and Persian sections of the Journal.

 

Contribution of Articles

Comments and articles are welcomed. Written assurance must be given that the article has not been published elsewhere. The author will be notified of the acceptance, ejection, or need for revision as soon as possible. Please submit a brief description of your educational and professional background and, if possible, a photograph.

 

TAX INQUIRIES

Readers who may have questions about the Iranian tax laws and procedures are encouraged to submit their inquiries for review. The inquiries will be reviewed by high-level tax specialists and, space permitting; the answers will be published (together with a summary of questions) in the journal. Otherwise, the answers will be sent directly to the inquirers.

 

The End

 

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