Limits of legality of tax optimization: new risks for business

The article analyzes changes in the Tax Code of the Russian Federation concerning the limits of the legality of tax optimization. Definitions are given to such concepts as tax optimization, economic, material, tax benefits, tax risks. A comparative analysis of the provisions of the new art. 54.1, clause 5 of Art. 82 of the Tax Code of the Russian Federation and Decree No. 53 of the Supreme Arbitration Court. The results are summed up, what consequences the entrepreneur has for himself after the introduction of the changes.