islamic economic renaissance 363tries share some similarities but have a few distinct differences. The
similarity is mainly that the two countries introduced Zakàh to their
systems around the same time, 1980 and 1982, for Pakistan and
Kuwait respectively, and the differences are in that the economic
and socio-political set-up of the two countries is vastly different. It
is a case of comparing the implementation of Zakàh in a rich petro-
leum country like Kuwait and a less fortunate country where poverty
is more desperate such as Pakistan. Conceivably, the level of geo-
graphical dispersion in the country is expected to influence the size
and shape of the administrative structure and the level of wealth is
anticipated to influence the choice of the method for collection. Khan
found that the organizational structure of the administrative body of
Zakah in Pakistan comprised of five hierarchal layers (central, provin-
cial, district, tahsil, and local) while that of Kuwait was largely cen-
tralized. Also, while the collection of Zakàh in Pakistan was found
to be obligatory, that in Kuwaiti was voluntary (ibid.).
The Sudan provides an interesting case study. It was the domicile
of the Islamic Mahdi reform movement in the late nineteenth century
that was founded by Mohammad Ahmed al-Mahdi (1844–1885) who
proclaimed himself the awaited Mahdi and who aimed to establish
an Islamic state in the Sudan. During the time of the Mahdi state,
Zakàh was implemented within the process of the Islamisation of
state administration. In the late twentieth century, Sudan took five
years to finalise the organizational structure of its Zakàh system.
Zakàh was reintroduced in two phases: (a) a voluntary phase in 1980
by the enactment of the Zakah Fund, and (b) compulsory in 1984
when the Zakàh and Taxation Act was passed. As al-Sawory explains,
the Zakàh control system in the Sudan is exercised at three different
levels: Sharì"ah control, financial control and administrative control.
He emphasises the need to provide Zakàh staff with proper train-
ing and ensure their adequate recruitment.
The importance of publicity on the distributing of Zakàh revenue
is stressed by Abdùllah in his study of Sudan. Abdullah believes that
Zakàh departments should disburse Zakàh in accordance with Sharì"ah
openly so that Zakah payers are reassured of the way in which Zakàh
revenue is used, otherwise a gap will always exist between the assess-
ment of Zakàh on available wealth and what is actually collected by
Zakàh departments (Abdullah, 1995).
The second main issue in the administration of Zakàh is the ques-
tion whether it should be obligatory, where Zakàh is regarded as a