Court confirms tax debt of 716,000 hryvnia over OnlyFans income

Appellate court upholds tax collection decision

The Third Administrative Court of Appeal ruled that Valeriia Ustyts's appeal is dismissed. The court confirmed the legality of the tax authority's actions and ordered the taxpayer to pay a debt of 716,248.16 hryvnia. This amount includes additional taxes and penalties on income earned from creating content on the OnlyFans platform.

Sources of income data

The court's decision was based on case materials and the results of a tax audit conducted after receiving information from the competent authority of the United Kingdom within the framework of international cooperation. The results of a documentary, unscheduled, non-visit audit established that during 2022, Valeriia Ustyts received $79,393 from the British company Fenix International Ltd. Since no tax declaration was filed for this period and no corresponding payments were made, the tax authority conducted a documentary, unscheduled, non-visit audit.

Debt amount and parties' positions

The tax authority determined an underpayment of personal income tax of 522,592.36 hryvnia and a military levy of 43,549.37 hryvnia. Additionally, penalties were applied, increasing the total debt to 716,248.16 hryvnia.

During the court hearing, Valeriia Ustyts denied receiving these funds and challenged the accuracy of the currency conversion to hryvnia. She provided no evidence of tax payments in the country of income origin or documents that would refute the official data obtained through international information exchange.

Reasons for the court's decision

The appellate court judges took into account that the facts of the payments are confirmed by official documents obtained within the framework of international cooperation. Since the plaintiff failed to provide counterarguments or evidence of tax payments, the court recognised the tax authority's actions as lawful. The decision of the first-instance court was left unchanged.