Business splitting through 130 sole traders: ESBU ensured the reimbursement of over 23.5 million UAH in taxes

 Over 23.5 million UAH of unpaid taxes was returned to the state budget based on the results of the investigation into a business splitting scheme in a meat products store chain. To reduce the tax burden, company officials processed the sale of goods through 130 controlled individual entrepreneurs.

Detectives of the Main Detectives Unit of the Economic Security Bureau of Ukraine established that during 2024–2025, the company sold meat products through its own chain of stores; however, a portion of the income was processed through 130 controlled individual entrepreneurs.

For this purpose, the enterprise initially sold them its own products and related goods at prices 5–30% lower than the final price in the stores. Subsequently, the company sold these goods to buyers on behalf of the individual entrepreneurs. In this manner, a portion of the sales income was accounted for by the entrepreneurs rather than by the company, which allowed it to pay fewer taxes.

At the same time, the individual entrepreneurs were only formally independent businessmen. They did not conduct independent activity and did not decide which products to purchase and sell. They were used for the artificial distribution of income of a single business.

As a result of such actions, 23.5 million UAH of taxes did not enter the state budget. The amount of damages was confirmed by the conclusion of a forensic economic examination.

The chief accountant of the company was notified of suspicion of tax evasion in especially large amounts under Part 3 of Article 212 of the CC of Ukraine.

During the pretrial investigation, the damages caused to the state were reimbursed in full. The materials of the criminal proceedings have been forwarded to court with a motion to release the suspect from criminal liability on the basis of Part 4 of Article 212 of the CC of Ukraine. The decision based on the results of its consideration will be made by the court.

Procedural guidance is carried out by the Office of the General Prosecutor.