Abstract: In his article Ivanov touches upon international taxation of foreign economic activity actors. The subject of the research is the problems caused by the dilution of the tax base and  profit shifting signified by OECD and the object of the research is the Russian rules for holding operations performed by companies. The author examines such aspects of the topic as controlled foreign corporations, transfer pricing and thin (insufficient) capitalization as well as geographical interests of Russian companies in relation to direct foreign investments. The author pays special attention to the motives that route Russian direct investments to aforesaid jurisdictions. The methodological basis of the research is the theoretical approaches to developing a 'neutral' tax policy in relation to investment activity of multinational companies, Russian tax laws and reports of the Federal Tax Service as well as results of a coordinated research of direct investments performed by the International Monetary Fund. The results of the research include the following conclusions: Russian regulations of intercompany operations are based on international recommendations and allow to control foreign trade transactions that are 'sensitive' for the budget. The stucture of foreign direct investments from the Russian Federation demonstrates understandable business motives and entrepreneur goals that require the government to improve taxation and business conditions of economic, i.e. international, company's activities as well as participation in international exchange of tax information. Coordination efforts applied by OECD create a new legal basis for international taxation that would require modern conditions of business operations.