The criteria for distinguishing between reasonable and unreasonable personnel expenses is not a new topic, but its relevance is growing: firstly, due to the increased fiscal burden on business, and secondly, due to the increased interest of the tax authorities in such transactions in 2024. 

Head of Tax Compliance Practice Ivan Tsvetkov commented on the tax aspects of personnel expenses in RBC's article. This issue has become particularly relevant in light of Daniil Egorov's interview: due to the introduction of increased personal income tax burden from 2025, bonuses paid by organisations in 2024 will become the subject of special attention of the inspectorate (the tax authorities expect organisations to pay large bonuses on purpose in 2024 before the provisions on increased rates come into force). In our practice, in order to successfully defend, firstly, the economic justification of bonuses, and secondly, the presence of the organisation's intention to pay them specifically for 2024, it is necessary to: 

Documents confirming the relation of payments in the form of bonuses to the organisation's remuneration system

Bonuses existing in the company should be mentioned in labour contracts with employees and, preferably, the provisions of such labour contracts should contain a reference to a local regulatory act on bonuses - for example, a bonus policy. The need to have such a document in an organisation is confirmed by the Ministry of Finance. [1]