A tax, as defined by taxation experts, is an obligatory due imposed on the payers and submitted to the state. Taxes are usually imposed according to the ability of the payers and regardless of the benefits the payers derive out of the services performed by the public authority with the tax proceeds. Tax proceeds are used for public expenditure to achieve economic, social, political , and other objectives of the state.1 Zakah, as defined by Muslim jurists, is a determined right imposed by God on the wealth of Muslims, to the benefit of the categories mentioned in God's Book, such as the poor, the needy, etc.

It is an expression of gratitude for God's graces, and is performed to seek His pleasure and to purify souls and wealth.

The above definitions reveal the following similarities:

1. The elements of obligation and compulsion exist in both zakah and taxes.

2. Both taxes and zakah are paid to certain public body, be it the local or national authority2 or an autonomous institution, or the public treasury.

3. In taxes, there is no reciprocity between the amount collected and services received by the payer. The payer is required to pay taxes as a member of society. Zakah is also paid, without any direct exchange, by every Muslim to the Islamic state, regardless of the benefits that the zakah payer may get from the state.

4. Zakah and, in their modern philosophy, taxes, have social, economic, and political objectives besides their financial objective.

Outside the above points of similarity, differences between zakah and modern taxes are numerous:

1. The first striking difference is the name, which has important indications. Zakah as a word means purity, growth, and blessing. The word is selected for this pillar of Islam in order to incorporate these meanings in zakah. "Tax" implies imposition, estimation, and charge. The Arabic word for tax, "Daribah", has the same indication of charge and imposition. God says "And they were covered [duribat] with humiliation and miserliness."3 Consequently, a tax is looked upon as a charge and liability. While zakah inspires purity, sanctity, and growth. It is implied that hoarding wealth without cleansing it by giving the right God imposes to the poor makes wealth a source of sin and evil, and that giving zakah -- though it reduces the wealth -- in fact brings reasons for growth.

God says "God will deprive interest of all blessing, but will give growth for deeds of sadaqat."4 "And nothing do ye spend in his cause but he replaces it." and the Messenger (p) says, "Wealth never decreases as a result of sadaqah."6

Moreover, zakah gives the feeling of purification not only for assets zakted but for the payer himself as well as the recipient, for it purifies from vanity, hatred and selfishness provides a benevolent hand to the poor. God says, "Out of their wealth take sadaqah that so thou might purify and sanctify them."7

2. The difference in nature and substance Zakah is a worship in gratitude and thankfulness to God, while taxes are a mere civil obligation. Intention is one of the conditions of zakah, since all acts of worship require intention. God says "And they have been commanded no more than this: to worship God, offering him sincere devotion."8 Zakah is always cited in the sections on worship in books of Islamic jurisprudence, and is mentioned in more than twenty places in the Qur'an. Zakah is not obligated on non-Muslim citizens of the Islamic state, since Islam does not consider it fair to obligate non-Muslims to perform an Islamic rite of worship.

3. The third difference is in ratios and minimum exempt, zakah -- as an obligation from God -- is irrevocably defined and its main features given by the Legislator.

Shari'ah determines the ratios applied on all assets, decreeing cases to which twenty percent, ten percent, five percent, or 2.5 percent rates apply. These ratios and their applicability cannot be altered by anyone or any law, regardless of changing circumstances.9