Kyiv court orders OnlyFans creator to pay UAH 1.48 million in taxes

On 17 September 2026, the Kyiv District Administrative Court issued a ruling that set a precedent for tax disputes involving earnings from international online services. The court dismissed the lawsuit of a citizen who attempted to challenge tax notification decisions (TNDs) issued by the Main Directorate of the State Tax Service in Kyiv.

How the tax authority identified untaxed income

According to the materials of case No. 320/11546/26, the basis for the unscheduled audit was information received by the State Tax Service of Ukraine from competent authorities in the United Kingdom. The data exchange took place under the framework of the bilateral Convention for the Elimination of Double Taxation.

The British side provided Ukrainian tax officials with detailed information about the creator, including:

• personal data of the individual;
• the total amount of transactions for 2023;
• information on fund transfers to electronic wallets, specifically via PayPal.

It was established that during 2023, the blogger received income of US$132,342 from the British company "Fenix International Ltd", the owner of the OnlyFans service. In hryvnia equivalent, this amount is approximately UAH 5.02 million. The creator did not declare this income and failed to pay the due taxes.

Defence arguments and the court's position

The plaintiff's representatives in court insisted that she did not create content on the OnlyFans platform, does not have an account there, and did not receive funds from "Fenix International Ltd". The defence also claimed that the correspondence between tax authorities in Ukraine and the United Kingdom does not constitute primary documents within the meaning of the Tax Code, and that the audit was initiated with procedural violations.

The court completely rejected these arguments, justifying its decision as follows:

• Information received from foreign tax authorities under international agreements constitutes official tax information and a lawful basis for additional assessments.
• The plaintiff failed to provide evidence (bank statements or other documents) that would refute the fact of receiving funds or confirm the absence of income.
• A statement on fund movements provided by the plaintiff herself confirmed top-ups to her card via electronic payment platforms (PayPal), which aligns with the data from British tax authorities.

Amount of additional assessments and fines

As a result of the audit, the tax authority issued five notification decisions, which the court deemed lawful. The total amount the creator is obliged to pay to the budget exceeds UAH 1.48 million. The distribution of funds is as follows:

• Personal Income Tax (PIT): UAH 904,800 (main payment) and UAH 452,400 (fine);
• Military Levy: UAH 75,400 (main payment) and UAH 37,700 (fine);
• Fines for failure to file a declaration and failure to provide responses or documents: UAH 11,707.