Journal of Tax Research

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The legislator, in pursuit of decentralization from the oil revenues system and the trend towards a tax-based system, has adopted the Direct Taxes Act on 1394/04/31 and, in Article 274 of the Act, without providing a definition of tax crimes and only after the expression Some examples of this economic crime have anticipated a sixth-grade punishment for committing such crimes. In this research, which was conducted through a library and descriptive-analytic study, by studying the specific elements of tax crimes and sanctions of them in the Act, it became clear that Iran's criminal policy against tax crimes was based on cases such as maximum criminalization, The lack of graded and effective of sanctions in relation to natural and legal persons, the lack of attempt and the inclusion of time lapse in some of these crimes, and more than being based on participation and preventive programs specialized, aimed at dealing with Tax Evasion, based on a more diverse criminal policy of a more repressive nature than our former tax rules

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The treaty is the best means of engagement and cooperation of countries in the field of international relations. Features such as order and precision, the determination of the scope and framework of rights and obligations in a treaty, has raised it as an explicit request by members of the international community. On the other hand, the conclusion of bilateral and multilateral tax treaties has given countries a favorable economic and political impact. Since most of these treaties have been concluded in accordance with the UN Model Tax Convention and the Organization for Economic Co-operation and Development, Governments wishing to conclude bilateral and multilateral treaties tend to seek to harmonize the provisions of their tax treaties And pursue goals such as confronting disproportionate agreements, abusing agreements, avoiding false standing in agreements, and eventually drafting laws to improve dispute resolution mechanisms such as referring to compulsory arbitration  and  Each of these bilateral agreements and international treaties, both at the regional and at the transnational level, can have effects such as the harmonization of international tax rules in the international system.
 

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Today, accountability to responsibilities and responsibilities is not only the responsibility of the government, but citizens also have a major responsibility in this area. From this point of view, what seems unavoidable is the need for joint cooperation between citizens and the government and citizens with citizens in order to achieve their rights. The main goal of this research is designing a model for the operation of citizenship rights in the organization of tax affairs of the country. The statistical population in this study was the total taxpayers in Tehran, and the sample size was determined by James Steven's formula of 300 people. The research methodology is a survey, the most important of which is the ability to generalize the results. The fitting of the proposed model was done through structural equation modeling in three parts of the model of measurement, structural model and the whole model and by Smart PLS 2.0 software. After examining all the research hypotheses were approved, and finally, some suggestions were made.

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Extraordinary proceedings are one of the common legal mechanisms besides ordinary proceedings which deals with the claims of individuals within the framework of a specific legal system. A look at repeated article 251 shows that the subject of this article is the extraordinary tax procedure and deals with tax claims within the framework of relevant laws and regulations. It looks like the legislator has been summarized in this article and there is a kind of legal vacuum regarding tax filing mechanisms in this article. One way out of such a vacuum is to extend the legal principles to this article. The question in this regard is: What are the criteria and legal principles surrounding the repeated Article 251 of the Direct Tax Act? In answer to this question, using the research method: The descriptive-analytical conclusion is as follows: First, some legal principles are explicitly extractable from the text of the article, such as the documentary and reasoning principle. Secondly, some principles of law, such as the validity of the judgment, can be deduced from the scope of the general principles of law and the context of the matter. Thirdly, these principles are the most important indicator for the refinement and clarity of the article, as they are written in the absence of the text, they are the guiding light for tax authorities.

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