Odesa court orders woman to pay 356,000 UAH in taxes on OnlyFans earnings

The Odesa District Administrative Court ruled in favour of the tax authorities, ordering Mariia Pidhirna to settle a debt of 356,219.13 hryvnias. These funds cover taxes and fines assessed on income received from the British company Fenix International Ltd, the owner of the OnlyFans platform. Simultaneously, the court dismissed the plaintiff's counterclaim, in which she attempted to challenge the additional liabilities.

How tax authorities learned about foreign payments

Information regarding the payer's financial transactions became known to Ukrainian tax services through the mechanism of international exchange of tax information. Competent authorities in the United Kingdom provided data on payments made to Pidhirna for creating content on OnlyFans in 2021 and 2022.

The total amount of funds received was 41,846 US dollars. The breakdown by year was as follows:

• 2021 — 11,693 dollars;
• 2022 — 30,153 dollars.

Conversion at the National Bank of Ukraine exchange rate on the last day of the respective reporting periods resulted in a sum of 1,421,616.99 hryvnias. Of this, 318,963.99 UAH corresponded to 2021, and 1,102,653 UAH to 2022.

Since the woman did not submit declarations of property status and income for the specified periods and did not pay taxes, the State Tax Service initiated a documentary unscheduled audit. Written requests and orders were sent to the payer's official address, but postal shipments were returned after the storage period expired.

Following the audit, the tax service assessed the following liabilities:

• 255,891.06 UAH in personal income tax (PIT) and a fine of 63,972.76 UAH;
• 21,324.25 UAH in military levy and a fine of 5,331.06 UAH;
• 8,000 UAH fine for failing to respond to a tax request;
• 680 UAH for failure to submit declarations.

The corresponding tax demand was issued on 7 August 2025.

Arguments of the parties in court

Mariia Pidhirna filed a counterclaim, denying the fact of receiving funds from the British company. She claimed that the tax service had not proven the fact of payments and also cited the possibility of taxing this income in the United Kingdom under the Convention on the Avoidance of Double Taxation.

The court did not accept these arguments. The evidentiary base included information obtained through international exchange and an official response from the British competent authority. It contained the payer's personal details, her email address, city of residence (Odesa), and transaction amounts.

The court noted that such information can be used by tax authorities as a valid source of data on foreign income. Once the fact of receiving funds was confirmed, the obligation to declare them and pay taxes fell on the payer. She was required to provide evidence of tax payments abroad or refute the receipt of income, but no such documents were submitted to the court.

The court also deemed the conduct of the audit and the sending of requests and tax decisions lawful, as the tax service complied with the requirements of Articles 42 and 79 of the Tax Code of Ukraine.

Final court decision

The Odesa District Administrative Court fully upheld the claim of the Main Directorate of the State Tax Service in Odesa Oblast. A decision was made to collect 356,219.13 UAH in tax debt from Mariia Pidhirna.

The structure of this amount includes:

• 320,543.82 UAH in PIT;
• 26,655.31 UAH in military levy;
• 9,020 UAH in penalty sanctions.

The court fully refused to satisfy the counterclaim seeking the cancellation of tax notification-decisions and the tax demand.