ZZ consultants have won a contract from the Russian government to advise on small company accounting regulation and to provide training for government officials and educators. Some of the contract will be performed by staff in ZZ’s Moscow office, but they will be helped by staff transferred from their offices in Germany, the UK and Switzerland. If the rate of corporate income tax in Russia is 80 per cent, in Germany 60 per cent, in the UK 35 per cent and in Switzerland 25 per cent, how would you advise them to structure their internal transactions? Should all the staff to be used be transferred to the Moscow office or should Moscow be invoiced from other locations with staff flown in and out to meet specific assignments?