Elena Smirnova
Elena Smirnova
Leading Transfer Pricing Expert

Elena is one of the key specialists of G&A in the field of transfer pricing and tax control of prices.

As part of her work at IBFS / Guskov & Associates, Elena was involved in projects to prepare a justification for the correspondence of prices of intra-group transactions to the market level, and also successfully defended clients of interest to the tax authorities on transfer pricing issues. Prior to joining IBFS, Elena worked for the Big Four companies.


Tax specialist, Plekhanov Russian University of Economics


  • Development of an intra-group transfer pricing policy.
  • Preparation of supporting documentation for controlled transactions in accordance with Russian and European standards.
  • Determination of market price ranges and profitability.
  • Creation of a calculation model for the formation of prices for intra-group transactions at the market level.
  • Protecting the interests of clients when the tax authorities file claims that prices do not match the market level.
  • Formation of an expert opinion on the compliance of prices with the market level within Art. 54.1 of the Tax Code of the Russian Federation (unjustified tax benefit)


  • Transfer pricing ▶︎