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Maliyat Journal, No. 14

 

Winter 1996-97

 

 

 

IN THE NAME OF ALLAH

 

FROM THE PRESIDENT

 

We have always pointed out that the promotion of tax knowledge of our readership constitutes one of the main goals of this journal. Such an undertaking would naturally have broad dimensions, and would cover vast areas of tax issues and problems. One interesting and important subject of this kind is the issue of the interpretation of tax laws and regulations.

It is interesting to know that the topic is quite new in this country, and nobody have ever tried to elaborate on various aspects of this specific subject. The importance of the issue is due to the fact that the rights and duties of both sides of the tax system - namely the government and taxpayers - depend on how the laws are understood and deciphered.

The main question is: whether the tax laws and regulations are to be construed according to certain rules and principles or not, and if the answer is positive, what are those maxims and rules of interpretation?

As far as the necessity of interpretation is concerned, the answer is certainly positive. It is impossible for those who formulate or approve the law, to foresee and anticipate all circumstances that will govern the atmosphere in which the law is going to be implemented.

The time passes and the economic life of the society - that makes up the principal ground for execution of tax law - is apt to alter and evolve uninterruptedly. Let us take the current tax law as an example. This law (Direct Taxation Act) was approved in March 1988, say less than a decade ago. During this very short period, vast and tremendous changes have taken place in the varieties and volume of transactions, the form and substance of economic relations, and many other factors that have direct or indirect effects on taxes and taxation affairs.

The people who were involved in deliberation and approval of the said law logically were not able to foresee all these changes and developments. The best evidence for this statement is the large number of circulars, by-laws, and other types of rulings issued for explanation of the same law.

This is an unavoidable process which is prevailing all over the world and among all categories of countries and societies. So, first we have to determine a viable policy in this regard. Have we to leave the matter as it is, or have we to regulate it through appropriate legal channels, so that a reasonable and clear way of action could be founded?

The next question is: whether the tax law must be treated as any other law (for instance civil law) and subject to the same rules and methods of interpretation adopted in respect of ordinary regulations? Or, we have to consider the tax law as a separate category requiring special rules of construing and deciphering?

In case of choosing the latter approach, what are those rules and principles of interpretation which suit the tax regulations?

More questions of this kind can be raised. Our aim is to draw the attention to the issue in general, with a view to cause a movement in direction of research and study towards this significant topic. Maliyat journal considers - as always - its duty to take an active part in this type of research and deliberation. The subject has been reviewed in some articles of the present issue, which we hope to draw the attention of tax experts and practitioners, and to be starting point for evolution of clear approaches in this field.

 

Dr. Aliakbar Arabmazar

 

 

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TREATY DEVELOPMENTS

 

A COMMENT ON RECENT TAX TREATIES CONCLUDED

 

WITH A DOZEN OF FOREIGN COUNTRIES

 

(Part 2)

 

BY Dr. Mohammad Tavakkol

 

As we mentioned in the last issue of this Maliyat journal, Iranian tax administration has taken remarkable steps towards the expansion of international tax relations with other countries. Many tax treaties are concluded, or are at the stage of negotiations, which would increase the number of such type of agreements to a level unprecedented in this country.

We mentioned also that all these treaties are drawn on basis of a prototype or pattern agreement, which in its turn is based on the OECD Model Double Taxation Convention on Income and Capital. Therefore, we chose the OECD Model and the said pattern agreement, as well as one of the signed agreements - namely the Iran-Ukrainian agreement - as the bases of our discussion. The subjects commented on in the last issue were: "title of treaties", "personal scope", and "taxes covered" by the agreements under review.

Now the study will continue as follows:

 

General Definitions (Article 3)

Article 3 of the Iranian tax treaties is divided (like the OECD Model) into two paragraphs or sections. Section one presents definitions for several terms, and section 2 states that any term not defined in the agreement " shall, unless the context otherwise requires, have the meaning which it has under the law " of the relevant states. It means that in case of terms and expressions not defined in the agreement – neither in Article 3 nor elsewhere - have the contracting parties to interpret the term according to their internal regulations.

The words defined in paragraph 1 of Article 3 of the agreement are as follows:

A) Contracting State "the term 'a contracting state' and 'the other contracting state' mean the Islamic Republic of Iran or Ukraine as the context requires; the term Islamic Republic of Iran means the territories under the sovereignty of the Islamic Republic of Iran. The term Ukraine when used in geographical sense, means the territory of Ukraine, its continental shelf and its exclusive (maritime) economic zone, including any area outside the territorial sea of Ukraine which in accordance with international law has been or may hereafter be designated as an area within which the rights of Ukraine with respect to the sea bed and sub-soil and their natural resources may be exercised."

Some points are worth of mentioning with regard to the said definition:

1. The term so defined, namely "contracting state", is not found among the definitions of Article 3 of the OECD Model. It has been added through the bilateral agreement of the parties to the Iranian treaties.

2. As it could be seen, the above text is somehow different in respect of the definition of”

Ukraine ". Definition of Iran is - in comparison with Ukraine - very short and it refers to the territories under the Iranian sovereignty only. The term Ukraine, on the other hand, has been defined broadly, and includes not only “the territory of Ukraine", but also that country's continental shelf, exclusive maritime zone, etc.

3. Most of the modern tax treaties contain broad definition of areas under sovereignty and control of the contracting parties. It seems that the above short definition of " " is borrowed from the old tax conventions of this country concluded with Germany (1968) and France (1973).

Although the definition of Iran in those old conventions is similar to newly concluded agreements, nevertheless there is a small - but significant - difference between those two types of treaties. The definition given in the old conventions is as follows:”

The term Iran means the territory of the Empire of ", while the new agreements define the same word as: “territories under the sovereignty of the Islamic Republic of Iran

The word territory when used in singular means the geographical area under the sovereignty of a state. It includes the land, internal waters, and territorial sea. When we use the same word in plural, and say: 'Iran means the territories under the sovereignty of this country', one might think that some separate geographical regions are meant. It would not be easy to infer, from such an expression, the idea of a whole and integrated political unit.

4. More important is the fact that the term "Ukraine" includes not only the "territory" of this country, but its continental shelf and economic zone as well, while in case of Iran no reference has been made, either to the continental shelf or to the economic zone.

As a matter of fact, the jurisdiction of coastal states over the continental shelf is not the same as they have over their main territories. The control they may exercise with regard to continental shelf can not be termed as "sovereignty ", though they may practice some exclusive rights over the natural resources of this area. So, the continental shelf can not be categorized as a "territory under the sovereignty" of a coastal state.

This being the case, one might ask whether the Iranian party did not want the treaty to apply to the continental shelf of this country. We must remember that Iran is very active in its continental shelf, and it would seem quite strange if it would have negative attitude towards the application of its tax regulations - including double taxation treaties - to the vast economic activities performed in such regions.

4. The other face of the coin - which seems more probable - is that the Iranian party did not mean the exclusion of continental shelf from the geographical scope of the treaty. If so, the text of the treaty - as regards the definition of Iran - has to be amended, with a view to extend it to the continental shelf and economic zone.

 

B and C) Person and Company

The agreements under discussion follow the suit of the OECD Model in defining these two words. We had some comments on both of them in the previous issue of the journal.

D) Registered Office. This is another term which is not defined in Article 3 of the OECD Model. Registered office means - according to the Iranian new agreements - head office of an enterprise registered under the relevant laws of either contracting state. One of the occasions in which the term "registered office" is used, can be found in paragraph 3 of Article 15. It pertains to the "remuneration derived in respect of an employment exercised aboard a ship, boat, aircraft or road and railroad vehicle operated in international traffic". This type of remuneration "may be taxed in the contracting state in which the registered office of the enterprise is situated”. The same term is used also in paragraph 3 of the Article 22, according to which "Capital represented by ships, boats, aircraft, road and railway vehicles operated in international traffic...shall be taxable only in the Contracting State, in which the registered office of the enterprise is situated

Comparing these two paragraphs with the relevant sections of the OECD Model, one can see that "place of effective management” in the Model has been substituted for the "registered office” in the Iranian treaties. Perhaps the reason for this alteration is to bring those cases to coincidence with the Iranian income tax regulations.

In case of companies and other juridical persons, the concept of "residence" is principally alike, both in respect of civil and commercial - as well as the taxation - affairs. This principle can be inferred from the Article 110 of the Direct Taxation Act (DTA). It provides that the taxation affairs of legal persons should be handled by the tax office of the district, where the residence of juridical person is situated.

The term "residence of juridical person" means - according to the commercial law - the place where such person is registered.

A company may have registered branches and subdivisions as well, but the term "place of incorporation” when used absolutely, means the central and principal office of a corporation. It seems that the same concept is followed by the Iranian double taxation treaties, since the head office of an enterprise is - in majority of cases - located in the same place where it is incorporated.

 

E) Enterprise

The terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" are defined exactly like the definition given in sub-paragraph "" of paragraph 1, Article 3 of the OECD Model. Such enterprises are those carried on by residents of the contracting parties.

 

F) International Traffic

Sub-paragraph "" provides a definition similar to the OECD Model, except for the following aspects:

- The Model defines the term as "any transport by a ship or aircraft", while the Iranian treaties cover "boat, aircraft, or road and railway vehicle- According to the Model, the ship or aircraft must be "operated by an enterprise which has its place of effective management in a Contracting State As it was mentioned above, an "enterprise of a Contracting State" means the enterprise carried out by a resident of either contracting parties. The criteria for deciding whether a person is resident of a state are provided in Article 4. Suppose an individual named "" is considered (for the purpose of the treaty) to be resident of both Contracting States. Suppose also that he has a home in Ukraine, but his office - through which he administers and controls his business of international traffic – is situated in Iran. Such a person has to pay his income tax to Ukraine, in spite of the fact that his economic activities are carried on in Iran. Therefore the criterion used by the OECD Model - that is place of effective management" - is preferable to the one mentioned in the Iranian agreements.

 

G) Competent Authorities

The term "competent authority" when used in these treaties, means "the Minister of Economic Affairs and Finance" in case of Iran, and "Ministry of Finance" in case of Ukraine. Both authorities can appoint a representative to work as "competent authority".

 

H) National

The term "national" which is not found in the OECD Model, means:

"1. Any individual possessing the nationality of a Contracting State;

2. Any legal person, deriving its status as such from the laws in force in a Contracting State".

At least the first of these definitions is redundant and does not actually provide a description for the Resident (Article 4)

The purpose of the Article 4 is to define the meaning of the term "resident" and to solve cases of double residence, since double residence may result in double taxation.

Paragraph 1 of Article 4 provides a general rule for determining whether a person is resident of a Contracting State or not. The concept of residence in these agreements has a particular scope. It has a taxation purpose and meaning. Resident means "any person who under the laws" of a Contracting State "is liable to the tax therein by reason of his domicile, residence, place of registration, or any other criteria of a similar nature". So, deciding on residency of a person is a matter of national taxation laws of contracting parties. To reach such a decision, no attention is necessary to be paid to the criteria adopted by the internal laws of the parties for determining the liability to taxation. That is why the problem of double residence may arise, for solution of which a special procedure is provided under the subsequent paragraph of the Article 4.

The said paragraph 1 of the Article 4 of the Iranian agreements differs from the OECD Model in two

1. The expression "place of management" in the Model (as a criterion of residence) is changed to "place of registration". We have already explained the reason why the Iranian party preferred the latter expression to the former, though the alteration seems redundant in this particular case. The phrase any other criterion of a similar nature “would cover "place of registration" as well.

2. A whole sentence at the end of paragraph 1, Article 4 has been deleted in the Iranian treaties. The deleted sentence reads: "But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein

The rule prescribed by that sentence, may be construed as pertaining to a situation where a person is national of, and domiciled and working in, a third country. Such a person may earn incidentally an income from the sources in a Contracting State, or he may own a property in that state. The second sentence (which is deleted by Iranians) would exclude these persons from definition of "resident". This exclusion means that the agreement is not applicable to such persons, since under Article 1, only residents" of Contracting States are subject to the agreement.

It is interesting to know that the situation described above, is very clearly foreseen by the main taxation law of Iran, that is the Direct Taxation Act. The Article 1 of the Direct Taxation Act (DTA) prescribes a general (and most important) rule for determining persons liable to Iranian taxation,

Among them, one can find the following categories:

- Iranian individuals residents abroad, in respect of income derived from sources in Iran;

- Non-Iranian persons (whether natural or legal) in respect of income derived from transfer of royalties; and

- Owners of properties located in Iran, in respect of capital tax on such properties.

Those are very clear examples of the taxpayers categorized under second sentence of paragraph 1, Article 4 of the OECD Model. Taking these facts into account, it seems curious that the sentence 2 is deleted from the text of the said paragraph 1. Did the parties really want to apply the agreement to such odd people? The answer hardly can be positive. Suppose that a resident of a Contracting State owns properties in the other Contracting State. Then the capital tax on such properties should be paid, not to the state in which they are situated, but to the other state in which the taxpayer has his residence. If this type of unnatural result is to be avoided, the deleted sentence is to be restored at the end of paragraph 1 of the Article 4.

 

Double Residence (individuals)

Paragraph 2 of Article 4 prescribes a procedure for solving the problem of double residence. This paragraph and the sub-paragraphs coming under it are in exact conformity with the OECD Model. A brief presentation of the procedure provided by the treaty is as follows:

- When an individual is considered (under paragraph 1) to be resident of both states, then he shall be deemed to be resident of that state in which he has a permanent home.

- If he has permanent home in both states, he shall be considered to be resident of the state in which his center of vital interests is situated.

- If such location can not be determined, or if he has not a permanent home in either state, then we have to find in which country he has a habitual abode.

- In case he has a habitual abode in both states, or in neither of them, he shall be deemed to be resident of the state of which he is a national.

- At last, if our individual is national of both states, or none of them, then the parties to the agreement should settle the question by mutual agreement.

 

Double Residence (persons other than individuals)

According to Paragraph 3 of Article 4 "Where, by reason of provisions of paragraph 1 of this Article a person other than an individual is a resident of both Contracting States, then it shall be deemed to be resident of the State in which its registered office is situated

As it was explained in the previous issue of the journal, the persons subject to the agreement can be divided into three categories: natural persons or individuals, legal persons (companies and other incorporated bodies), and semi juridical persons, namely the bodies of persons that are not considered legal persons as such, but at the same time they are treated as single taxpayers under the taxation law. Paragraph 3 pertains to categories 2 (legal persons) and 3 (semi juridical persons).

It provides that the issue of double residence in case of these two types of persons shall be solved by reference to the place of registration of their head offices. This is another case of substitution of the expression "place of effective management" (in OECD Model) with "registered office" (in the Iranian treaties).

 

 

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Tax News

 

UNJUSTIFIED PROTESTING

In a new circular of the Finance Ministry, the tax officials are instructed to refrain from filing unjustifiable protests against the verdicts rendered by the Boards of Settlement of Tax Dispute (BSTDs). BSTDs are bodies organized under the Direct Taxation Act (DTA) for reviewing and settling all kinds of tax disputes, both at the first and second instances. The cases can be brought before BSTDs, either by taxpayers or tax officials.

The final verdicts of BSTDs are also appealable before the Supreme Council of Taxation (SCT) on the ground of inconsistency with the laws and regulations or insufficiency of examination.

The substance of the Ministry's circular is that the protests and complaints of tax officials in all these cases should be based on justifiable grounds. They are prohibited from filing protests as such and without reasonable foundation and evidence.

Some of the points raised in the circular are as follows:

1. Although the officials are granted the right to protest against the verdicts of BSTDs, but this does not in any case mean that they are required to do so in all cases, without discrimination as to the existence or absence of justifiable grounds;

2. The verdicts issued by BSTDs are, as a common rule, rendered by consideration of facts and after sufficient deliberation;

3. Raising baseless and unsubstantiated complaints would result in prolongation of examination, wasting of time of BSTDs and of the officials themselves, and postponement of collection of taxes.

Based on this reasoning, the Ministry orders the officials to participate actively in deliberations of the first-instance BSTDs, and to provide all the evidence they may have in defense of their cases.

When, after such steps are taken, the BSTD delivers its verdict, the relevant tax official may protest against it, only if he has sufficient grounds and convincing evidence for his action. If there are no such substantiated grounds, he should refrain from protesting, otherwise he will be prosecuted by the High Disciplinary Board.

The same is applicable - according to the circular - with regard to filing of unfounded complaints with the Supreme Council of Taxation.

 

COMPLAINTS ARISING FROM THE PROCESS OF EXECUTION

If the taxpayer fails to pay his dues on time, the tax office shall take certain actions to collect such dues from him. A section of the Iranian Direct Taxation Act (DTA) is devoted to the process of issuing and enforcing the writ of execution in respect of unpaid taxes. The procedure and steps provided under this section of the law are called "the execution measures".

Any protest against the execution measures is to be submitted to, and reviewed by, the Board of Settlement of Tax Disputes (BSTD). Sometimes the complaint involves a special element, and that is the claim of the taxpayer to the effect that the process of execution took place before finalization of the related taxes. In such cases, the BSTD considers this particular claim and if finds it justified, it shall rule for cancellation of the writ of execution, and shall review the substance of the case, and issues its verdict on the liability of the taxpayer. (Article 216, DTA)

The Ministry of Economic Affairs and Finance has recently issued a circular in this respect. It has been stated in the circular that most of BSTDs do not actually pay due attention to the exact requirements of the relevant regulations. In other words, they enter in consideration of the substance of the case, without enough deliberation for finding if the relevant taxes are really finalized, or they have not passed yet the last stage of finalization. The circular instructs the BSTDs to be more accurate, and refrain from doing so, before being sure that the case is finalized.

 

INCOME TAX OF MEMBERS OF GUILDS

The income tax of enterprises operated by natural persons is titled - under the Direct Taxation Act (DTA) - as the business income tax. Such businesses are mostly associated with business unions or guilds. Under the Note 6 to the Article 100 of DTA, the Ministry of Finance may enter into agreement with those guilds about the determination of taxable income of their members. The taxes assessed in this manner shall be final and binding on both parties.

The procedure so defined used to be scarcely activated in the past. In recent years, however, more attention has been paid to the issue, both by the unions and the Finance Ministry. A considerable number of agreements have been concluded from which the members of the relevant guilds can take benefit.

A recent circular of the Finance Ministry refers to those agreements and discrepancies encountered in their implementation. As it can be inferred from the circular, such difficulties arise mostly from the attitude of some tax officials. They resort to various excuses for neglecting the agreements and to assess the tax liability of relevant people via ordinary and common procedures.

Some of those excuses are - according to the circular - as follows:

- A number of taxpayers have not been able to pay tax installments on time;

- Some others did mistake in computation of their liability, and paid less taxes than they had to The relevant tax offices claimed that those failing taxpayers breached their agreements by doing so, and therefore their taxes should be assessed without consideration of the agreements. They have also claimed in some cases that the real amount of tax liability can not be ascertained under the conditions of these agreements.

This approach has resulted in disapproval of the guilds and their members, as well as in increment of the number of tax disputes. The aim of the Ministerial circular is to stop this way of action, and to facilitate the implementation of the tax agreements concluded with those business guilds.

 

REVALUATION OF FOREIGN CURRENCY

The Supreme Council of Taxation (SCT) delivered recently an opinion on proceeds of enterprises from revaluation of their foreign currencies. According to paragraph "a" of Article 141 of the Direct Taxation Act (DTA) income derived from exportation of certain goods and products is wholly or partially exempted from taxation. Such enterprises keep accounts in foreign currency, which is apt to revaluation at the end of tax year. The SCT was asked to consider a situation where those enterprises earn proceeds from such revaluation, and to render its opinion as to whether such proceeds are subject to income tax, while the source of their income (namely the earning from exportation) was tax exempted. The Plenary Board of the SCT reviewed the matter and stated unanimously that those proceeds from revaluation of foreign exchange are subject to taxation, although the income from exportation of goods - from which the foreign currency is derived - was tax exempted. The income from revaluation - according to the SCT - is something quite different from exportation, and it is earned in a later stage. It is resulted not from the exportation, but from keeping the money for certain duration of time.

 

TRADE AGREEMENT BETWEEN IRAN AND SLOVAKIAN REPUBLIC

This agreement which has been recently ratified by the Parliament contains some tax regulations. Article 6 of the agreement reads as follows:

"The Contracting Parties shall provide, under their internal laws and regulations, exemption from custom duties, taxes and other levies for importation and exportation of the following articles:

a) Simples and items for advertisement; and

b) Containers and special packing equipment used as returnable items in international trade". The Article 8 of the same agreement provides for encouragement of economic institutions of both countries to participate in international fairs and markets, etc., organized in their territories. Pursuant to this purpose, the Article states:

"The Contracting Parties shall exempt - under their internal laws and regulations - the importation and exportation of the following items from custom duties, taxes, and other levies:

a) Accessories and articles imported for installing or repairing, provided that they will be exported later;

b) imported items for temporary fairs or markets, provided that they will be re-exported.

 

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ABSTRACT OF PERSIAN ARTICLES

 

EDITORIAL

The editorial in this issue, both in Persian and English sections, is devoted to the subject of interpretation of tax laws. The President has discussed the matter in broad and general terms, with a view to draw the attention of researchers and practitioners to the significance of this issue.

 

TAXATION IN PROVINCE OF KHUZISTAN

The Editor had an interview with Mr. Sayyed Abdorrassul Beladi, Director General of Economic Affairs and Finance of Khuzistan Province. Our readers are familiar with this series of interviews. The Economic situation of the Province in general, and taxation data in particular, are presented by the interviewee. The latter includes information about the level of taxes collected in recent years, degree of tax compliance by taxpayers, cases of success, bottlenecks and shortcomings, and several other interesting subjects and issues.

 

TREATY DEVELOPMENTS, A COMPARATIVE AND ANALYTICAL STUDY ON NEW TAX TREATIES CONCLUDED WITH SEVERAL COUNTRIES

This is the second part of the study undertaken with regard to the Iranian new tax treaties. In this second part, the author examines Articles 4 and 5 of the treaties. General definitions of some terms are presented in the Article 3, and Article 4 is devoted to the subject of residence. As it was mentioned in the previous issue, the agreements under discussion are generally drawn on basis of the revised OECD Model Double Taxation Convention. So, the study is concentrated on that Model, as well as on a prototype treaty that constitutes the basis of the Iranian agreements. One of the signed agreements, namely the one concluded with Ukraine, is also referred to article by article.

 

INTERPRETATION OF TAX LAWS

This is one of the articles printed in the present issue of the journal about the said subject, which has been also discussed by the President in more general terms in the Editorial. Several interesting ideas and principles evolved during recent decades in western countries in the field of this subject are deliberated by the author. Among those one can refer to the rule of the "substance over the form", economic interpretation of tax law", effectiveness of law", and other rules and maxims.

 

ENCROACHMENT INTO THE REALM OF THE SUPREME COUNCIL OF

TAXATION

The Supreme Council of Taxation (SCT) is the highest organ - under the Direct Taxation Act - for reviewing tax complaints and cases. The SCT has several branches and a Plenary Board. Decisions taken by the latter Board have the same value as the law, since they can not be altered except by a law or by the subsequent decision of the same Board.

There is also a judicial organ called the Administrative Court of Justice (ACJ) which has the authority to review and settle complaints against the measures taken by the various governmental organizations. As far as the taxation is concerned, the ACJ is competent to rule on the decisions of "tax commissions". The ACJ has construed the term "tax commission" to include the SCT and even the Plenary Board of that organ.

This subject and reasoning of ACJ about its competence to review the verdicts of the

Plenary Board of the Supreme Council of Taxation is dealt with in the article.

 

TAX AMNESTY IN SOUTH ASIAN COUNTRIES

Tax amnesty is a general phenomenon in this part of the world. The governments have resorted to this policy in many occasions. India and Sri Lanka are two distinguished examples. During the recent decades they experienced this policy several times, which mostly ended with failure. This subject is dealt with in the article with deliberation about the points of feebleness of effectiveness of the tool of tax amnesty.

 

TAX EXEMPTIONS AND DEDUCTIBILITY OF EXPENSES WITH REGARD TO IN-KIND BENEFITS OF WORKERS

The employers are reluctant to increase the main salary of their workers, since that would cause increment of their future obligations towards the workers, under the regulations of the labor law. They are more ready, instead, to compensate their workers by giving them facilities and other benefits in kind. The workers, on the other hand, agree with this way of action, because the in-kind benefits are exempted from taxation. Only tax officials are not happy with this process, since it results in less tax payable to tax organization.

The same creates difficulty in other respect. The employers want the in-kind benefits, to be accepted as deductible expenditures, while the tax officials are reluctant to do so.

Both sides of the issue are dealt with in the article. The author tries to solve the problem by referring to new rules of interpretation of tax laws (like the rule of substance over the form) and also by analyzing the text of the relevant regulations.

 

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."

 

TAX GLOSSARY

Several tax terms and expressions 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.

 

The End

 

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