The article is devoted to assessment of the enterprise investment attractiveness, based on the determining of degree of unsystematic risk in the part of capitalization rate. On the basis on certain integral indicators of economic performance of Ukrainian mining industry was calculated unsystematic risk premium that can serve as a criterion for investment decisions.

Since 2017 four of fifteen steps of the BEPS plan (base erosion and profit shifting) have been introduced in Ukraine to resist various areas of aggressive tax planning. The implementation of the BEPS plan is primarily made through frame working a transfer pricing control system in Ukraine, which aims to reduce illegal tax sheltering through foreign economic transactions with interdependent or interested parties as well as through transactions with contractors that are registered or make business in low-tax jurisdictions. The purpose of this study is to evaluate the results of implementation of European requirements in the system of audit of foreign economic activity in Ukraine. The study is based on data from the State Statistics Committee of Ukraine, the State Fiscal Service of Ukraine for 2015-2019.The article identifies the amounts of Ukrainian exports (imports) to (from) low-tax jurisdictions, analyzes the controlled exports and imports by geographical segment. The study presents evidence of the use of transfer pricing mechanisms by Ukrainian companies to optimize income taxation, which is contrary to the interests of the state. Therefore, a special need consists in improvement of the state control over operations of the foreign economic activity. The changes and current trends in foreign economic operations during the implementation of transfer pricing controls since 2013 in accordance with the BEPS plan were examined. This study proves that immediately after expanding the list of low tax jurisdictions, there has been a significant fall in the volume of controlled exports and imports, which we regard as a loss of cost-effectiveness of trade operations through low tax jurisdictions due to increased controls and enlarged list of territories, transactions through which are under strict control.

Evaluation of the reliability of enterprises engaged in the foreign economic activity and simplifying of Customs procedures have become a relevant issue in the context of globalization. The capabilities and preferences of the "Authorized Economic Operator" status are the cause of a new challenge for managers of enterprises-creation of an internal control system to ensure a systematic monitoring of the conditions of Customs compliance standards of reliability and safety, which would allow identifying risks of loss of the "Authorized Economic Operator" status. The purpose of the scientific paper is to improve the internal control system of an enterprise engaged in foreign economic activity in the process of obtaining and saving the "Authorized Economic Operator" status in accordance with the international Custom requirements for safety and reliability. Methodology. The research is based on the methods of logical and analytical modelling of the impact assessment of individual factors on the value of the generalization indicator. The results are tested on the internal accounting data of the existing machine-building enterprises. Results. The paper shows the results of adapting the concept of COSO to the system of internal control of the foreign economic activity of the enterprise in the process of obtaining or retaining the "Authorized Economic Operator" status. The internal control system within the concept of COSO should ensure the achievement of the objectives-operations, reporting, and compliance. The criteria for estimating the objective "compliance" for an enterprise engaged in foreign economic activity can be an integral indicator of compliance. Value/originality. It is suggested to perform internal control of an enterprise's compliance with Customs requirements based on the analysis of deviations of the compliance integral indicator. Practical implications. The result of control is to perform a steady increase in the integral index or stable maintenance of the already achieved indicator that will allow a company to maintain the "Authorized Economic Operator" status and perform foreign economic activities with simplified procedures. The indicators of total negative deviations and relative potential of rating are proposed in the paper. Total negative deviations by factors determine the degree of loss of quality characteristics of a company. The indicator of relative potential rating determines the percentage increase in the rating. Results of deviations evaluation by the blocks of the integral index of compliance will allow determining the certain aspect of a company activity, which did not meet Customs standards for the current period, and a responsible person who did not take care about the fulfilment of requirements of Customs standards, which introduces the risk of loss (non-receipt) of the "Authorized Economic Operator" status.

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