The ESBU ensured the reimbursement of UAH 23.7 million in unpaid taxes in a case involving business fragmentation by a supermarket chain

 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 fragmentation scheme. The UAH 23.7 million in damages caused to the state has been reimbursed in full.

The investigation established that the owner of a store chain operating in the Chernivtsi, Ternopil, and Khmelnytskyi regions organized a scheme of artificial distribution of activities among controlled Individual Entrepreneurs (FOPs). The illicit activity involved company officials and specific employees who maintained "black" bookkeeping and ensured that the FOPs' incomes did not exceed the legally established limits.

In effect, the business operated as a network of separate entities under the simplified taxation system, which allowed them to avoid paying VAT. According to expert findings, between January and September 2025, the total amount of taxes withheld from the budget exceeded UAH 23.7 million.

Currently, the head of the chain has ceased using the business fragmentation scheme, registered a Limited Liability Company (LLC), and now operates as a single business entity under the general taxation system. Employees who were previously registered as Individual Entrepreneurs (FOPs) are now officially employed.

The entrepreneur has been notified of suspicion under Part 3 of Article 212 of the Criminal Code of Ukraine. Since the damages were reimbursed in full prior to prosecution, a petition has been submitted to the court to release the individual from criminal liability.

Operational support was provided by the SSU Directorate in the Chernivtsi region, and procedural guidance was carried out by the Chernivtsi Regional Prosecutor's Office.