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Maliyat Journal, No. 13 - Autumn 1996
IN THE NAME OF ALLAH
FROM THE PRESIDENT
The tax administration declared lately that they
took some important steps towards the recognition of large taxpayers who have
always been attempting to keep away from the burden of taxation. The steps
resulted in collection of astronomic amounts of more than ten billion Rials in
case of some single taxpayers.
This movement, if followed continuously, could be
considered a good and inspiring beginning in several ways. First and foremost,
it can elevate the feeling of fairness and equity among the common people. Such
optimism is an imperative element and a must for raising the public sympathy
and readiness to accept the necessity of taxation, and to comply with legal
duties related thereto.
The term "tax culture" is used in this
country for such kind of public awareness and approach with regard to taxation
and tax duties. The authorities have always been emphasizing upon significance
of the "tax culture" and the urgent necessity of its promotion. Where
the predominant circumstances would allow the large taxpayers to evade
taxation, then not the "tax culture" but the culture of tax evasion
would prevail.
The success of the tax administration in
collection of the aforesaid enormous amounts of taxes, was due to developments
in the field of gathering and processing of tax information. The data and
documents were presented to the taxpayers and obliged them to accept their
dues. Computerization was an effective means for achieving such considerable
results. The tax administration is paying at the present more attention to
sophisticated services renderable by the computer. We hope that this new trend
would continue in the future. This journal has always pointed out that the demographic
changes of recent decades, as well as the unprecedented evolution of economic
and social activities, left no room for traditional systems of dealing with
taxation affairs. The number of taxpayers and volume of taxable transactions
have grown so enormously that makes the computerization the sole and
unavoidable solution.
The tax administration warned the taxpayers who
resort to offenses and tax evasion tricks. According to the authorities, some
taxpayers who have received the tax identification number (TIN) allow the other
people to use their TIN for entering into transactions that need such TINs.
Transactions so concluded shall be taken into consideration in computing their
own tax liabilities.
The importance of data gathering system is
referred to as the best means for finding and checking these types of tax
offenders. Another arrangement adopted by some taxpayers to reduce their tax
liability, is the division of taxable transactions between several cities. Thus
they would enjoy lower progressive tax rates. The tax administration declared
that the best measure to combat such kind of tax avoidance is to activate the
aggregate tax system. This system does already exist in the Iranian tax law,
but it is actually kept inoperative, because of certain difficulties
encountered in the past. Now by using the modern technology of data processing,
the possibility of vitalization of the system has become an achievable
perspective.
Dr.
Aliakbar Arabmazar
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TREATY DEVELOPMENTS
A COMMENT ON RECENT TAX TREATIES CONCLUDED WITH
A DOZEN OF FOREIGN COUNTRIES
BY Dr. Mohammad Tavakkol
Introduction
As
it was mentioned earlier in this journal, our country used to be counted among
the nations having the least number of international tax treaties. We had only
three double taxation treaties in the past, namely:
-
Convention for the Avoidance of Double Taxation with respect to Taxes on Income
and Capital concluded with Federal Republic of Germany on December 20 1968;
-
Convention for the Avoidance of Double Taxation and the Prevention of Fiscal
Evasion with respect to Taxes on Income, concluded with France on November 7,
1973; and
-
Agreement for the Avoidance of Double Taxation on Income from Shipping Activities
concluded with
This
situation was not on a proper scale with the actual position of the country in
the arena of economic and trade relations. To change this state of affairs, the
tax administration took remarkable steps towards the extension of international
tax relations with other countries. Negotiations with
Comments
on Treaties
All
agreements are drawn on basis of a prototype or pattern, which in its turn is
based on the revised OECD Model Double Taxation Convention on Income and
Capital. So we would concentrate our study on the same pattern, and one of the
signed agreements, namely the one concluded with
It
should also be mentioned at this stage that all new Iranian tax treaties are
drawn in three languages: Persian (Iranian national language), the language of
the other contracting states, and English. It has been stated in the last
paragraph of all treaties that
"In
case of any divergence of interpretation, the English text shall prevail".
We
will also base our study on English texts of the prototype as well as the Iran-Ukrainian
treaties.
Title of
the Treaties
The
word "agreement" is given to all new Iranian tax treaties, while the
previous treaties concluded between
The
first title, namely arrangement, is used frequently for treaties made with
regions which are somehow under the control of other states. For instance, the
following tax treaties of United Kingdom are titled as arrangements: Antigua
and Barbados (1947), Belize (1947), Burundi (1950), Dominica (19680, Falkland
Islands (1983), Solomon Islands (1950), Gold Coast (1947), Grenada 1949), Guernsey
(1952), Jersey (1952), Kiribati (1950), Lesotho(1949), Sierra Leone (1947), and
Uganda (1952).
Later
some of these regions and political units were recognized as independent states
(like Gold Coast which was named Ghana, Grenada, Lesotho, Sierra Leone, and
Uganda), and the title of their tax treaties was changed to
"agreement".
Words
agreement and convention are both used for tax treaties, but the term agreement
is gradually diminishing and the term convention takes its place in most cases.
Let us take the example of
Based
on what stated above, we would recommend that the name of new tax treaties be
altered to "convention", which is widely used in the contemporary tax
treaties.
Personal
Scope
Article
1 of the Agreement does not differ from the Article 1 of the OECD Model, except
that the term convention is changed to agreement. It reads as follows:
"This
agreement shall apply to persons who are residents of one or both of the
contracting states."
The
term person is defined in Article 3 (General Definitions) exactly like the
relevant section of the OECD Model. According to section "c" of
Article 3 (which corresponds to section "a" of the Model) "the
term person includes an individual, a company, and any other body of
persons"
.
The term "company" is also defined as "any body corporate or any
entity which is treated as a body corporate for tax purposes". This
definition is also identical with one adopted by the Model.
What
are worthy of mentioning here are phrases like:
"other
body of persons" "any entity which is treated as a body corporate for
tax purposes". These categories of
persons include bodies like partnerships, trusts, foundations, associations,
societies, unions, statutory undertakings, etc. We would call these bodies
"semi juridical persons", since they might not have legal personality
as such, nevertheless they are treated as a body corporate for tax purposes.
Some
of these creatures are not found in the Iranian legal system, and most people
know very little about them. Suppose that a contrary situation would exist in
domestic law of the other member of the treaty. Would such a difference of attitude
create difficulties on implementation of the treaty? Did the people who
prepared or signed the treaties deliberate on such potential problems? This is
a subject that should be dealt with in a separate study.
Persons
so defined will be subject to the treaty provided that they are residents of
one or both of the Contracting States. This aspect of the Article 1, namely the
subject of residence, is addressed in Article 4, which will be referred on when
considering the said article.
Taxes
Covered
The
Agreement "shall apply to taxes on income and capital imposed on behalf of
each Contracting state or its subsidiaries or local authorities, irrespective
of the manner in which they are levied." As it can be seen, the text of
paragraph 1 of Article 1 of the OECD Model is almost presented in this part of
the Iranian treaty. The same is true in respect of paragraph 2 which gives definition
of taxes on income and on capital.
Although
the kind of taxes covered by the treaty are described in both paragraphs 1 and
2 of the Article 2, but reference has been made in the same article to the
taxes in force at the time of conclusion of the treaty in each of the
contracting states. Paragraph 3 of the Article 2 presents a complete list of
existing taxes which are subject to the treaty. The paragraph reads as follows:
"The
existing taxes to which the Agreement shall apply are in particular:
a)
in the case of Islamic
1.
the income tax; and
2.
the property tax.
.........
b)
in the case of
1.
the tax on profits of enterprises; and
2.
the income tax on citizens.
As
far as the Iranian side of the treaty is concerned, direct taxes are covered by
the Agreement and they are divided to two main categories, namely the
"income tax" and the "property tax". These terms, headings,
and divisions correspond exactly to the Iranian Direct Taxation Act (DTA). DTA
is the only comprehensive taxation law of the country and consist of five main
chapters. Chapter one is the shortest one, and defines the persons subject to
taxation. The last chapter, namely Chapter 5 deals with procedural matters
relating to the organization of the tax assessment authorities, and those of the
organs responsible for settlement of tax disputes. Some miscellaneous matters
are mentioned in Chapter 3. The most important subjects covered by this chapter
are: cases of tax exemptions, deductible expenses, indications and coefficients
for ex officio assessment of taxes, etc.
Chapter
2 and 3 constitute the substantial part of DTA. Taxes covered by the law are
all mentioned under these two chapters: taxes on income and taxes on property.
The concept of income tax as reflected in DTA is, more or less, the same as
understood by the tax specialists everywhere in the world. The second category
may, however, represent some difficulty in understanding. The term property tax
under DTA covers firstly some kind of taxes which could be really defined as
taxes on capital. Theses kinds of taxes are all pertaining to immovable
properties.
In
addition to that, the term property tax covers also stamp duties, and
inheritance tax. It is useless to search for reasons why these taxes are
classified as property tax, and the important thing is that they are there in
DTA and they are considered as "property tax".
It
is not also our case to argue if such taxes are, or not, really property taxes.
The issue is that the inheritance tax becomes subject to a double taxation
treaty which is not - in principle - pertaining to inheritance tax. It is clear
that the treaty under review is typically a treaty on income and capital taxes.
It is also a well established fact that inheritance and gift taxes are
addressed in other kind of double taxation treaties.
Other
Indications - There are other circumstances in the treaty that are indicative
of the fact that it is not made to deal with the subject of inheritance tax:
1.
The treaty is based on, and copied from, the OECD Model, which does not deal
with the inheritance tax.
2.
The title of the treaty does not cover the inheritance tax.
3.
Going through the articles of the treaty, one can not find any references to
inheritance.
4.
The existing taxes of the Ukrainian party subject to the treaty are also listed
in paragraph 1 of Article 2. None of them has any relation to the inheritance
tax.
Conclusion
- One can gather from the above
reasoning that non of the parties had in mind to apply the treaty to the case
of inheritance tax. Why it is there in paragraph 3 of the Article 2, is a
subject that occurred possibly unintentionally. Anyway, this is a mistake that
must be corrected by the parties in appropriate manner.
Further
Amendments Since new taxes may be imposed and alterations may be done in the
existing taxes after conclusion of the agreement, paragraph 4 provides that:
"The
agreement shall apply also to any identical or substantially similar taxes
classified in accordance with definition of paragraph 1 of this Article which
are imposed after the date of signature of this agreement in addition to, or in
place of, the existing taxes..."
By
comparing this text with the relevant part of the OECD Model Convention, one
can see that the phrase: "classified in accordance with paragraph 1 of
this Article" is an addition to the original text.
This
phrase which has been inserted inside the paragraph 4, refers to the definition
of Article 1, and thus makes the paragraph 4 of Article 2 dependent on Article
1. The consequence is that in the future attention should be paid also to the
interpretation of Article 1. This not only may complicate implementation of the
agreement, but it would also eliminate the advantage of paragraph 3 of the Article
2. The latter determines concretely all existing taxes which are covered by the
treaty. It is much easier and much more safe to base our future judgment on
this tangible being, instead of resorting to some general and absolute
expressions.
The
original text of the OECD Model is free from this complexity. Paragraph 4 of
Article 2 comes immediately after the paragraph 3 and its reference is only to
the previous paragraph. It might be interesting to know that in a similar
double taxation treaty concluded between the same country (
(FURTHER COMMENTS
IN THE NEXT ISSUE)
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Tax News
WITHHOLDING TAX AND STATUTE OF LIMITATIONS
Under
the Article 85 of the Direct Taxation Act (DTA), the employers paying salaries
to their employees are required to withhold the applicable salary tax and to
pay the same, within 30 days, to the relevant tax office.
Article
90 of DTA relates to a situation where the employer fails to comply with the
aforesaid duty. In this case, the tax office shall calculate the applicable tax
and claim it from the failing employer. Taxes so calculated and demanded are
considered final under the Article.
Nevertheless
the employer has the right to protest, in which case the issue shall be
referred to the Board of Settlement of Tax Disputes for reviewing.
Article
157 of DTA on the other hand, states that the liability of the taxpayer become statute-barred
after expiry of a period of three years from the tax payment deadline, provided
that no claim is put forward by the relevant tax office during that period.
A
new circular of the Finance Ministry refers to the regulations of the said
article and states:
1.
The statute of limitation provided in the Article 157 must be taken into
account in implementation of the Article 90. It means that the claim of the
deferred salary tax by tax offices ( as referred to above) should take place
before the relevant taxes are statute-barred. Otherwise, the statute of
limitation will govern and the employer who has failed to withhold and pay the
salary tax, can reject the demand of the tax office.
2.
There is an exception to that rule. If the employee withholds the applicable
tax, but he fails to remit the same to the tax office, then the statute of
limitation shall not effect the case and the employer will have to pay to the
Ministry taxes so withheld, even if the said three years period is expired.
The
logic behind this ruling is as follows:
A.
When an employer withholds certain percentage of his employee's salry, the
money so deducted does not belong to him. It is rather a property of the
government. Then if the employer would fail to transfer the money so deposited
with him to its legal owner, he must be considered as a debtor who refrains
from payment of his dues. Therefore the statute of limitation provided for in
the Article 157 can not be applied, because it is pertaining to taxpayers
solely, and not to the ordinary debtors.
As
far as the ordinary debtors are concerned, no statute of limitation does exist
in this country. The old regulations of the civil procedural law containing
statute of limitation, all were canceled by the Council of Constitutional
Guardians, since they were considered to be contrary to the principles of the
Islamic canon law.
DATE OF COMMENCEMENT OF RESPITE FOR PROTESTING
Tax
disputes are to be settled by an organ called the Board of Settlement of Tax
Disputes
(BSTD).
The decision of the BSTD is final, except where the taxpayer or the relevant
tax office would file a protest within one month from the date of notification
of BSTD's verdict. The question pertains to the subject of notification.
Notification to whom? As far as the taxpayer is concerned, the wording of the
law is quite clear. The decision of the BSTD must be notified to the taxpayer,
and the one month respite for his protesting begins exactly from the date the
verdict is notifies to him.
But
the case is not so clear in case of the tax officers. The relevant part of the
Article 274 states:
"If
the tax assessment official shall, within one month after the date of
notification of the decision of the BSTD, file a protest in writing..."
As
it can be seen from the above text, the recipient of the notification is not
mentioned.
Notification
to whom, the taxpayer or the tax official? This question was raised and
referred to the Supreme Council of Taxation for reviewing and expressing an
opinion.
The
SCT reviewed the matter in its Plenary Board, and since the members of the
Board could not reach unanimous decision, two separate opinions were rendered
by the majority and minority members of that organ.
OPINION OF THE MAJORITY
The
Majority based its opinion on the fact that two separate paragraphs in the
Article 274,
DTA
are stipulated for taxpayers and tax officials. In the first paragraph the
right of protesting is granted to the taxpayer. The respite for the taxpayer's
protesting is also provided in the same paragraph. Then another separate
paragraph provides the same matters in respect of the tax official.
This
separation of cases means - according to the Majority - that the issue of
notification must also be viewed separately. The Majority stated at the end
that the date of commencement of the respite for protesting is different in
respect of the parties to the dispute. The date of notification of BSTD's
decision to the taxpayer or the tax official must be considered as the beginning
of one month period of protesting respectively for each of them.
OPINION OF THE MINORITY
The
minority members of the SCT's Board expressed a different view. According to
them, the date of notification to the taxpayer must be regarded as the
beginning of one month period of protesting for both the taxpayer and the tax
official.
The
Minority referred to another article of the same part of the law, which reads
as follows:
"The
taxpayer or the chief assessor concerned may, within one month from the date of
notification of the final decision of BSTD... file a complaint with the Supreme
Council of Taxation..."
Here
the date of notification on the taxpayer is regarded as the commencement date
of the respite for protesting, not only in respect of the taxpayer but for the
tax official as well. This – according to the Minority - is an appropriate and sufficient
indication that should be taken into consideration for solving the question
under discussion,
ACCRUAL BASIS
Section
2 of the third chapter of the Direct Taxation Act (DTA) is devoted to
deductible expenses and depreciation charges. The expenditures accepted as
deductible are listed in the Article 148 of the same chapter. This article is
very long and has 27 paragraphs and three notes.
A
circular issued recently from the Ministry of Economic Affairs and Finance
announces:
"Whereas
questions have been arisen about the acceptability of some deductible expenditures
- including those covered by the paragraphs 17 and 18 of the Article 148 of DTA
- that are not paid out up to the end of each fiscal year, and in order to
eliminate uncertainties in this regard, with the aim of adopting an unanimous
approach;
It
is hereby confirmed that deductible expenditures that are realized - according
to verifying evidence and documents - during a certain year, should be accepted
as deductible expenditures of the same year, whether they are actually paid or
undertaken by the taxpayer."
This
circular clearly emphasizes the accrual basis, according to which expenses are
brought to account when they are incurred rather than when they are paid. It
refers to clauses 17 and 18 of the Article 148 in particular. The reason is
that the verbs used in both paragraphs are in past perfect tenses. Therefore,
everybody would take them as meaning expenses that are actually paid out. The
circular refers to these paragraphs in order to prevent such type of interpretation.
IMPORT DUTIES
The
High Council of Commercial and Industrial Free Zones (consisting of several
ministers) adopted an amendment to the regulations for collecting duties from
importations to these zones. The amendment reads as follows:
1.
Raw materials and machinery: - 0 - to 10% of the CIF value.
2.
Intermediate goods and auxiliary materials: 3% to 40% of the CIF value.
3.
Durable consumer goods: 5% to 45% of the CIF value.
4.
Used goods and equipments: 15% to 45% of the CIF value.
5.
Luxury and other goods: 5% to 50% of the CIF value.
Note
1. A discount equal to 20% of the accrued duties shall be granted in case of
the goods, the documents of which would indicate that they are imported from
the country of origin.
Note
2. A discount of 10% of the accrued duties shall be granted for the goods in
relation to which a representative agent would exist in the country for
after-sale services.
COMPUTERIZED INVOICE SYSTEM
Sales
invoices issued by enterprises are considered as supporting documents against
the figures registered in statutory books of businesses. Manner of keeping
books, documents and records of taxpayers are regulated by several articles of
Section 4 of the second chapter of the Direct Taxation Act (DTA), and a special
by-law adopted by the Ministry of Economic Affairs and Finance.
Article 95, DTA provides that:
"The
statutory books for tax purposes mean the journal..., the ledger..., or any
special books supplied by the Ministry of Economic Affairs and Finance".
Note
3 to the same article states:
"The
Ministry of Economic Affairs and Finance may agree with other pattern of books
and means of keeping accounts".
Article
8 of the By-law concerning the manner of keeping the books referred to above provides
for preparation of accounting forms and papers (including invoices) by the computer.
Some persons and companies have obtained the agreement of the Finance Ministry
-
on basis of Note 3 to Article 95 DTA and Article 8 of the said by-law - to use
computerized invoices for their transactions.
Now,
a ministerial circular instructs those who have obtained the above permission,
to insert serial numbers on their computerized invoices, otherwise they would
be obliged to keep printed invoices (with serial numbers on them) according to
models provided by the Ministry.
A NEW APPROACH TO THE INTERPRETATION OF LAW
The
text of a letter from the President of the country to the Council of
Constitutional Guardians is published in the Official Gazette. According to the
Article 98 of the Iranian
Constitution,
the Council of Constitutional Guardians is vested with the power to interpret the
Constitutional Law.
The
president asked the Council of Guardians to render an opinion with regard to
the priority of conflicting ordinary laws upon each other. It has been
mentioned in the letter that in one single date two conflicting regulations
were adopted by the Parliament. The first one was the Budget Law of the Iranian
solar year of 1374 (21 March 1995 to 20 March 1996), and the second one was the
Law concerning the Method of Collection of Some Public Revenues.
Both
laws contain regulations pertaining to tax and other revenues. Several cases of
conflicting does, according to the presidential letter, exist between these two
laws. The
Budget
Law was itemized as the sixth, and the Law concerning Revenues as the seventh
items of the agenda of the same session of the Parliament. In cases where two
regulations are contradictory to each other, priority must be given to the most
recent regulations. Since the aforesaid laws were adopted on the same date and
the same session of the Parliament, the President asked the Council of
Guardians to deliver its opinion with regard to this unique and unprecedented
case.
The
Council answered that in case of contradiction between the laws enacted by the
Parliament,
priority should be given to the law which is adopted in a more recent date. If
both regulations are enacted in the same date, the one adopted in the most
recent hour shall have priority. In cases where both regulations are adopted
simultaneously, the date of recognition of the Council of Guardians must be
taken into consideration for determining the priority under discussion.
The
Council of Guardians is the competent organ, under the Iranian new Constitution
to review the laws adopted by the Parliament with a view to find whether they
agree with the principles of the Constitution, as wella as with the Islamic
canon law (Shari,a). The law becomes operative after such kind of recognition
by the Council of Guardians takes place.
The
Council stated, in its response to the President, that in case of conflicting
regulations adopted simultaneously, the one recognized by the Council at a
later time shall have priority over the other one.
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ABSTRACTS OF PERSIAN ARTICLES
EDITORIAL
The
Vice Minister for tax revenue declared recently that important steps are taken
by the Finance Ministry for recognition of large taxpayers who used to escape
taxation in the past. The achievements reached in this respect were, according
to the Revenue vice Minister, due to computerization and developments in the
field of gathering and processing of data and information. The editorial of the
Persian section is devoted to those statements. The same is dealt with in the editorial
of the English section as well.
TAXATION IN THE
An
interview wax held by this journal with Mr. Hossein Mohseni, Director General
of Economic Affairs and Finance of the
A COMPARATIVE AND ANALYTICAL STUDY ON NEW TAX TREATIES
CONCLUDED BDTWEEN
All
new agreements are drawn, more or less, on basis of the revised OECD Model
Double Taxation Convention on Income and Capital. The study undertaken by the author
is concentrated on the same Model Convention and one of the signed agreements,
namely the one concluded with
DOES THE IRANIAN TAX SYSTEM MOVE TOWARD THE ACCRUAL BASIS?
Under
the accrual method, items of income and expenditure are brought to account when
they are earned or incurred. According to a new circular of the Finance
Ministry, justifiable expenditures incurred during a certain fiscal year, are
deductible for determination of taxable income of the same year, even if they
are not actually paid in that year. This means that the accrual basis is
acceptable to the Iranian tax administration. The circular covers expenditures
only, and it does not deal with the income side of the issue. This article
discusses the subject matter of the circular, as well as the line adopted by
the Direct Taxation Act with regard to the items of income.
COUNCIL OF CONSTITUTIONAL GUARDIANS AND A NEW METHOD FOR
INTERPRETATION OF THE LAW
The
Budget Law of the Iranian solar year of 1374 (1995-1996) and the Law concerning
the Method of Collection of Public Revenues, were adopted by the Parliament on
one and the same date. Both of them contain regulations concerning the tax and
other similar revenues. Since both laws were adopted simultaneously and in the
same date, and both contain conflicting regulations, the Council of Constitutional
Guardians delivered an opinion which prescribed a new method for determining which
of the contradictory laws should be given priority. The author analyzed the
case and the opinion of the Council of Guardians. The same subject is dealt
with in the English section of this issue (under the heading: A New Approach to
the Interpretation of Law).
EUROPEAN ECONOMIC INTEREST GROUPING, A NEW LEGAL CREATURE WITH
TAX CONSEQUENCES
The
aim of this article is to introduce EEIGs to the Iranian readership. The
history of creation of EEIG is briefly presented, then the rules of the
relevant Council Regulations of EEC about formation, management structure, and
other characteristics of EEIG is reviewed. The main part of the Article is
devoted to tax issues related to the said groupings.
TAX AND ACCOUNTING SYSTEMS
In
RULINGS AND REGULATIONS
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."
TAX GLOSSARY
Several
tax terms are presented and defined in each issue of Maliyat journal. Detailed
explanations follow the definition of the terms.
LETTERS AND INQUIRIES OF READERS
The
inquiries of our readers related to different tax matters are answered by tax
experts. Readers in other countries also can address their inquiries to us.
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,
rejection, 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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