From "fragmentation" to transparent business: another network of over 20 stores in Bukovina emerged from gray schemes

 A network of over 20 stores of frozen semi-finished products in Bukovina stopped using the artificial "fragmentation" scheme to minimize taxes. The business shifted to a transparent model of operation and continues its activities within the legal framework.

Detectives of the Territorial Office of the ESBU in the Chernivtsi region established that the effectively single business was distributed among dozens of individual entrepreneurs. To minimize tax obligations, about 20 controlled IEs were used, among which income from product sales was artificially distributed.

The IEs operated using shared resources – staff, premises, equipment, and management. Their interconnection was also confirmed by shared contact data, IP addresses, objects of taxation, and tax reporting.

According to the investigation data, from January to December 2025, the cumulative income amounted to nearly 90 million UAH, which exceeded the limit of income for a single taxpayer of the II group.

The entrepreneur was required to switch to the general taxation system and register as a VAT payer. However, he failed to do so, which resulted in the actual non-receipt of over 15 million UAH in taxes to the budget.

The entrepreneur was notified of suspicion of committing a criminal offense provided for by Part 3 of Article 212 of the Criminal Code of Ukraine – intentional tax evasion, which resulted in the actual non-receipt of funds to the budget on an especially large scale.

During the pretrial investigation, the enterprise fully reimbursed the unpaid taxes.

And most importantly – the business refused the "fragmentation" scheme and transferred its activity to the general system of taxation. In the future, taxes will be paid from the real volume of economic activity, which creates a foundation for stable tax revenues in the future.

"For us, it is important not only to detect a violation and return funds to the budget, but to achieve systemic changes in the operation of business. The network reimbursed over 15 million UAH of unpaid taxes, stopped using controlled IEs, and switched to the general system of taxation. This is a comprehensive result of the work of the ESBU: stopping an illegal scheme and the transition of business to a transparent model of operation," emphasized the Deputy Director of the ESBU, Pavlo Buzdyhan.

Due to the full reimbursement of unpaid payments, a motion was sent to the court to release the entrepreneur from criminal liability. The final decision in the case rests with the court.

Operational support – Department of the SSU in the Chernivtsi region. Procedural guidance – prosecutors of the Chernivtsi Regional Prosecutor's Office.