the comparative study of ijarah sukuk between iran, malaysia and england law

this paper is a comparative study of legal aspect of islamic securities (sukuk), between iran (as shia fiqh) malaysia (as the first country that issued sukuk based on sonni fiqh) and england (as a chief western country in sukuk). results indicate many similarities between iran and malaysia rules despite specifications with england rules. different in definition of contract, asset valuation, limitation for securities profit, etc… show that britain rules emphasized on issuing sukuk due to making turnover and developing tax, without attention to real economical activities.keywords: islamic securities (sukuk), iran law, malaysia law, england law, ijarah sukuk.