The Odessa District Administrative Court declared all tax notices-decisions, which assessed a woman over UAH 250,000 in debt for allegedly received income from the OnlyFans platform, unlawful.
The Odessa District Administrative Court declared all tax notices-decisions, which assessed a woman over UAH 250,000 in debt for allegedly received income from the OnlyFans platform, unlawful.
What happened
The tax office received data from the British competent authority that the Ukrainian woman received payments from Fenix International Ltd (owner of OnlyFans) in 2021–2022 — a total of $34,218. On this basis, she was assessed personal income tax, military duty, and fines totaling ~250,000 UAH, and then a tax lien was opened on the property.
The woman stated that she had never registered on OnlyFans and had not received any income.
Why did the court overturn everything?
The court drew attention to the main problem: the inspection report was based solely on a letter from the State Tax Service with a reference to British data — two files in .txt format with the total number of transactions without dates and amounts for each. No primary documents — bank statements, contracts, confirmation of account registration — were provided.
The court also stated that OnlyFans requires identity verification (a photo with a passport/ID) to create an author’s account. However, there is no evidence that this particular woman was verified.
Regarding fines for failure to provide documents upon tax requests, the court noted that the plaintiff did not actually receive any letters: all items were returned by mail after the expiration of the storage period. And failure to receive mail is not yet proof of intentional evasion, as required by the Tax Code of Ukraine for prosecution.
Main conclusion
Tax information from a foreign authority is a reason for an audit, but not proof of income. An audit report cannot be based on assumptions.
The tax office also collected a court fee in favor of the plaintiff — UAH 2,502.
Why is this important?
This is not the first such case: Ukrainian tax authorities actively use international data exchange to identify income from OnlyFans, Patreon and other foreign platforms. But this decision shows that information from a foreign regulator alone without supporting documents for each transaction is not sufficient grounds for additional assessments.
