پژوهشنامه مالیات
سال بیست و دوم شماره 69 (بهار 1393)

Since introducing globalization theories in recent years, international trade volume and as a result trade transactions volume especially between related parties have been increased. Multinational companies have tried to avoid paying tax by establishing extensive networks of related parties around the world through TP mechanism, so TP and its auditing in recent decays have become more important issues in tax systems of different countries. In this paper by using library studies, first of all, different aspects of TP have been explained and then tax related issues of TP examined in Iranian tax system. The results show that although TP regulations are not included in tax laws explicitly but in some cases by using the circulars of tax administration, the tax authorities can implement the Arm's Length Principle and then deter tax avoidance and tax evasion resulting from TP mechanism.

Capital Gains Tax (CGT) is one of the major bases of tax systems. Establishing CGT in Iran can help tax system in fulfilling three objectives (including optimal resource allocation, income distribution, creating sustainable revenue sources for the government). This type of tax can be imposed on the difference of the value of capital, the value of buying and selling assets, etc after deducting some costs such as depreciation costs, costs of investment and so on. One of the goals of this type of tax is prevention of speculative activities in capital assets market like real estate market. Therefore, capital tax rate is based on short-term holding period which is more than the rate based on long-term holding period. This issue aims at separation of consumption demand from speculative demand and speculative demand control of assets.

What makes two recent centuries, different from previous ones are not wars, revolutions, scientific discoveries and so on, but this difference is due to continuous economic growth which is resulted from using fossil fuels. In the situation where sanctions have sharpened its blade for the pressure on Iran’s economy more than past, reducing oil dependence will be more important & considerable. One of the ways to reduce oil dependence is raising the state income tax from which much of the national budget should be obtained. The purpose of this research is to determine the effect of total income tax on economic growth. In this survey the tax status of some selected countries of the Middle East and North Africa (Egypt, Jordan, Morocco, Tunisia and Cyprus during the period of 8 years from 2002 to 2009) have been studied. The method which has been used in this study is panel data.

Inheritance and transfer of legacy to the deceased’s heirs is not a new issue. This issue and its related clear regulations have existed in all civilizations and societies worldwide. Inheritance tax together with the other common taxes have been devised, introduced and implemented in the developed countries and other countries followed them. This paper seeks to review these questions: 1. Is there any financial obligations on legacy in Islamic teachings knowing that Islam has focused on it and there are related and detailed decrees in Koran and sonnat? 2. Is there any form of inheritance tax in the ancient Islamic governments or even in the other caliphs’ rules? If the answer to these questions are negative, what is the decree related to inheritance taxation? Is it considered one of the cases of “vacuum zone theory”? 4. What is the position of inheritance tax in the other countries? 5. Which of the documents (i.e. current laws or the reviewed bills in Iran) are more consistent with the studies’ results? For answering these questions, the sufficient studies should be done in the other countries of the world in a descriptive method by three jurisprudential, historical and comparative approaches and finally the current law and proposed bill should be evaluated and views and recommendations should be presented for more consistency with the studies done.

The government financing has a significant place in the economic literature due to its distribution and allocation impact. In this study the government revenue resources are classified into two categories: “hard to earn” and “easy to earn” revenues. The main question is whether the increase in the share of export revenues earned by selling natural resources which is considered as a component of “easy to earn” revenues prevent the increase in the share of “hard to earn” revenues in the MENA region? And if so, whether existence of SWFs (sovereign wealth funds) in these countries has the ability to prevent an adverse effect of the natural resource revenues on “hard to earn” tax revenues? To answer these questions, panel data of 21 countries in the MENA region from 1990 to 2012 are used. The results show that increasing the share of natural resource revenues in GDP reduce the share of “hard to earn” revenues of governments in the MENA region. In fact, increasing the share of natural resource revenues will replace tax revenue share. Moreover, the SWFs have passive role in some countries and they have not been able to affect government financing.

Knowledge management covers all processes and activities related to creation, achievement, sharing and use of knowledge and resulted expertise and skills. The ability of distinguishing between knowledge and raw data enables the organization to change the information into related and appropriate knowledge and to achieve their goals. The present study is trying to identify factors affecting knowledge creation in Iranian National Tax Administration (INTA), and suggests an optimized model for establishing the knowledge management system in this organization. In the first section, effective factors on knowledge creation in the organization are identified and ranked through applying One-Sample T test and Friedman test. Statistical population was the employees of the INTA headquarters, and sampling was carried out in a simple random manner for 149 persons. In the second section related models of knowledge Management are being studied; and an optimal model is provided for the establishment and deployment of Knowledge Management system in INTA relying on an integrated approach for the preparation of the prerequisites, culture, implementation, and finally knowledge evaluation and audit.

The positive effects of equal income distribution on macroeconomic variables such as productivity, economic growth and poverty reduction and consequently economic and social welfare improvement on one hand, and adverse effects of income inequality on social variables such as crime and delinquency on the other hand, have made equal distribution to one of the major concerns of economic officials of the country. For this reason, over the recent decades, an extensive literature has been devoted to achieve an equitable income distribution and investigation into the determinants of income distribution improvement. This study has attempted to investigate the effects of different types of tax as well as some other factors on one of the most important inequality indicators (GINI index) in Iran’s provinces by a Bayesian Econometrics Approach and applying Bayesian Model Averaging (BMA). Finally, according to the theoretical and empirical evidence, it is found that Kuznets’ hypothesized inverted U-shaped relationship between economic development and income distribution is supported by data.

The main purpose of this paper is, to design a dynamic model for evaluation of economic and tax policies on Iranian tax system by using system dynamics approach. For this purpose, we consider the tax effort, tax capacity and tax evasion subsystems. The simulation of this model has been accomplished during 2008-2025. The results of base model simulation show that, if current situation continues, situation of tax effort and tax evasion will not in good position and in 2025, only 66 percent of expected tax will be collected. Also the extent of tax evasion in years of the final simulation will be 35 percent. For study of necessary conditions in order to access to optimal status, different scenarios have been designed and simulated. The results of simulations show that, in order to access to the desired status, in addition to coordination and interaction among the variables, some attempts should be done simultaneously to reduce the inflation rate, increase welfare, and decrease the activities in underground economy, increase population growth, per capita revenue and taxes (taxes on consumption and import).