If there is a collective bargaining agreement, it may envisage specific rules for the Salary Supplements; however, such an amount should be within the salary for the Additional Work. In case of non-specification of the Salary Supplements, the court may specify them taking into account the complexity of the work, its nature, scope, the level of use of the working hours and the employee's salary (Paragraph 15 of Resolution of Plenum No. 13).
In addition, recent court practice confirms the necessity of the payment for the Additional Work (Resolution of Supreme Court in case No. 824/238/19-а dated 24 October 2019).