Appeals court reduces OnlyFans creator's tax debt to 8,000 hryvnia

The Sixth Administrative Court of Appeal has concluded its review of the case concerning the taxation of income earned by a Ukrainian creator on the OnlyFans platform. On 5 October 2026, the panel of judges issued a ruling that cancelled a significant portion of the tax liabilities imposed on the taxpayer.

According to the materials of case No. 320/46413/25, the lawsuit filed by Anna Vyacheslavivna Shilo against the capital office of the State Tax Service (STS) was upheld. The court deemed most of the additional assessments unlawful, leaving only the penalty sanction in force.

How the conflict with the tax authority arose

The events began after the Ukrainian tax authority received information from the competent authorities of the United Kingdom. The data was provided by Fenix International Ltd, the operator of the OnlyFans platform. According to this information, a Ukrainian user allegedly received income exceeding 109,000 US dollars from content creation during the period of 2021–2022.

The STS classified these funds as undeclared foreign income. Since annual declarations had not been submitted, tax officers assessed a total amount of nearly 970,000 hryvnia. This sum included personal income tax (PIT), the military levy, and fines.

Tax officer errors identified by the court

The appellate instance established that the tax authority had acted formally, ignoring basic requirements for the evidentiary base. The court pointed to two key violations:

• Problem with identifying the account owner. The international certificate from the United Kingdom did not contain correct data: the taxpayer identification code (RNOCP), patronymic, and the plaintiff's exact address were missing. The STS failed to documentally confirm an unequivocal link between the foreign virtual accounts and a specific citizen of Ukraine.
• Errors in currency exchange rate calculation. Instead of converting each transaction at the National Bank's exchange rate on the date the funds were actually received, as required by the Tax Code, inspectors simply summed up the annual receipts and converted them into hryvnia at the rate as of 31 December. This significantly distorted the tax base.

Court ruling

The court upheld the cancellation of the additional assessments for PIT, the military levy, and fines for non-declaration. The only lawful penalty recognised was a fine of 8,000 hryvnia. The court justified this by noting that the creator had failed to provide explanations in response to an official written request from tax officers at the time.