Tax authorities charged an OnlyFans model with a debt of over 100 thousand hryvnias — court made a decision in the case

The Ivano-Frankivsk District Administrative Court denied the Main Department of the State Tax Service in the Ivano-Frankivsk region the collection of 128.6 thousand hryvnias of tax debt from a local resident. 

Circumstances of the case

According to the case materials № 300/6861/25, the tax authorities filed a lawsuit to recover from the woman more than 111.4 thousand hryvnias of personal income tax, 9.2 thousand hryvnias of military tax, and 8 thousand hryvnias of penalties.

The basis for the debt calculation was information about the possible receipt of income by the woman from the British company Fenix International Ltd, which owns the OnlyFans platform. According to the tax authorities, it concerned payments for content creation amounting to about 13.5 thousand dollars.

In court, the woman denied the existence of the debt and stated that the tax notices-decisions are illegal. She emphasized that the conclusions of the State Tax Service are based solely on an informational letter that does not confirm the fact of her receiving the funds.

According to the defendant, the tax authorities did not provide evidence of actual income receipt — in particular, bank statements, payment documents, contracts, or information about specific transactions.

The court examined documents obtained by the Ukrainian tax authorities from the competent authority of the United Kingdom. They contained information about the OnlyFans user account, indicating the city of residence as Burshtyn and the payment method through an electronic wallet.

At the same time, the documents did not include data on specific payments, transaction dates, amounts of individual transfers, full bank account numbers, or confirmation of actual crediting of funds.

The court also noted that the account information mentioned the company Fenix International Ltd and 24 transactions totaling 13.5 thousand dollars, but without details regarding individual payments and evidence that the payments were received by the defendant herself.

Court decision

After reviewing the case materials, the judge denied the tax authorities' claim. Additionally, on July 24, the court initiated proceedings on the woman’s lawsuit against the State Tax Service, in which she requests the cancellation of the tax authority’s decision on the debt calculation.

As previously reported by the "Judicial and Legal Newspaper", the adult digital content creation industry is one of the most dynamic sectors of the creative economy, where Ukrainians hold one of the leading positions worldwide. However, this success is accompanied by a legal paradox, as Ukraine finds itself in a situation where the State Tax Service actively demands millions in budget revenues, while the law enforcement system continues to massively open criminal proceedings for creating the same content.

Until recently, judicial practice in cases related to the OnlyFans platform was chaotic, as lower courts trusted analytical reports from the State Tax Service obtained through international exchange. However, June can be called a period of establishing judicial control over the State Tax Service’s attempts to blindly tax digital income.

Within one week, the Supreme Court made two important decisions — on June 17 in case № 240/22077/25 and on June 25 in case № 560/9531/25, which defended content creators. These decisions proved that the presence of information from foreign authorities (HMRC) is only a trigger for verification, not automatic proof of the taxpayer’s guilt. The situation where the tax authorities manually match OnlyFans data to Ukrainian surnames, first names, and patronymics received an assessment from the highest judicial instance.