Optimisation of taxation by business entities is controlled by the Federal Tax Service of Russia, which gives rise to an increasing number of claims and disputes regarding the amount of income between related parties and, accordingly, the amounts of taxes calculated. Among other things, interest is aroused by remuneration payments to managers who take the place of a full-time manager in a company.

The list of methods of tax control over the financial results and terms of such transactions is closed and is defined by Clause 1 of Article 105.7 of the Tax Code. At the same time, a combination of them is allowed, which in practice is not always realised in a logical form.

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