8.6 million UAH in unpaid VAT: the ESBU in Bukovyna exposes another business splitting scheme

 Detectives of the Territorial Office of the Economic Security Bureau of Ukraine in the Chernivtsi region have completed a pre-trial investigation into a case of tax evasion through a "business splitting" scheme. The damages caused to the state, totaling 8.6 million UAH, have been repaid in full.

The investigation established that the head of a company involved in the retail food trade under a well-known brand organized a scheme for the artificial distribution of commodities and cash flows through controlled individual entrepreneurs (FOPs).

Employees of the enterprise were involved in the illegal activity; they were registered as individual entrepreneurs and used to sell products to end consumers. At the same time, actual management and control over financial transactions, personnel, premises, and equipment were carried out by a single center.

In reality, the business functioned as a single economic entity but was formally divided into separate individual entrepreneurs under the simplified taxation system, which allowed for the avoidance of value-added tax (VAT) payments.

According to the analytical study and forensic economic examination, it was established that during 2025, the enterprise evaded VAT payments totaling over 8.6 million UAH.

Currently, the head of the company has been notified of suspicion under Part 2 of Article 212 of the Criminal Code of Ukraine (intentional evasion of taxes, fees, or other mandatory payments).

Since the damages were repaid in full prior to the person being held liable, a motion has been filed with the court to exempt the individual from criminal liability. Procedural oversight is provided by the Chernivtsi Regional Prosecutor's Office.

In total, ESBU detectives in the Chernivtsi region are investigating 16 criminal proceedings regarding the splitting of businesses by local networks. In 2026, four cases have already been referred to the court.

At the same time, two more enterprises have abandoned such schemes and switched to the general taxation system.

The total amount of funds restituted to the budget in these proceedings amounts to almost 50 million UAH.

It should be noted that, according to Article 62 of the Constitution of Ukraine, a person is presumed innocent of committing a crime and cannot be subjected to criminal punishment until their guilt is proven in accordance with the law and established by a court's verdict of guilty.