Sharia and Legal Legitimacy of Zakat Deduction from Tax Base Laws: A Comparative Study

Abstract

Objective: The objective of this study is to examine the Sharia and legal legitimacy of deducting zakat from the tax base under contemporary financial laws. The study aims to clarify whether such a deduction can be justified from an Islamic jurisprudential perspective and modern legal frameworks, while assessing its impact on fiscal justice and taxpayers’ financial obligations. Theoretical framework: The theoretical framework of this study is based on Islamic jurisprudential principles governing financial obligations, particularly zakat, alongside contemporary legal theories of taxation and fiscal equity. It adopts a dual approach that combines classical fiqh concepts with modern public finance principles to analyze the relationship between religious duties and state-imposed taxes. Literature review: The literature review covers classical Islamic jurisprudential sources on zakat and public levies, as well as contemporary academic studies addressing taxation, fiscal justice, and zakat management. It also examines comparative legal literature and institutional reports discussing tax deductions and financial policies in Muslim-majority countries. The review reveals a lack of integrated studies that jointly address Sharia and legal perspectives on zakat deduction. Methods: This study employs a qualitative research methodology based on doctrinal legal analysis and comparative jurisprudential examination. Selected contemporary financial laws are analyzed and compared with established principles of Islamic jurisprudence to assess the legitimacy and conditions of deducting zakat from the tax base. Results: The results indicate that zakat deduction may be considered legitimate under certain Sharia and legal conditions, particularly when it prevents double financial burden and promotes fiscal justice, provided that clear regulatory frameworks are established. Implications: The study provides practical guidance for legislators and policymakers seeking to harmonize zakat obligations with modern tax systems while ensuring fairness and transparency. Novelty: This study offers an original comparative analysis that bridges Islamic jurisprudence and contemporary financial law in addressing zakat deduction policies.