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.
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