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On 19 October 2026, the Rivne District Administrative Court issued a ruling in case No. 460/12666/26, fully dismissing the claim. The court supported the position of the State Tax Service of Ukraine regarding the additional tax assessments and the application of penalty sanctions against a citizen who earned income from creating content on the OnlyFans platform.
The basis for conducting an unscheduled audit was information received by the State Tax Service from competent authorities in the United Kingdom as part of international tax data exchange. The British side provided details on payments made by Fenix International Ltd, the owner of the OnlyFans service, to Ukrainian residents.
During the audit, it was established that in 2023, the claimant Sofia Sverdlyuk received 11 payments totalling $4,252. At the National Bank of Ukraine exchange rate, this amount is equivalent to 161,501 hryvnia. The woman did not reflect these funds in her annual declaration of property status and income, which the tax authority qualified as an underestimation of the tax base.
As a result of the control measures, the State Tax Service assessed personal income tax in the amount of 29,070 hryvnia and a fine for its non-payment of 7,267 hryvnia. Additionally, a military levy of 2,422 hryvnia and a fine for its non-payment of 605 hryvnia were accrued.
In addition to financial liabilities, the tax authority applied fines for procedural violations:
The total amount of all tax assessments and fines exceeded 48,000 hryvnia.
The plaintiff argued that correspondence between tax authorities of different countries cannot be considered a primary document. She also emphasised that she has been living abroad for the past few years.
The court rejected these arguments. The ruling noted that data received from the British authority in accordance with international agreements can serve as a proper basis for determining tax liabilities. Furthermore, the court took into account that the OnlyFans platform requires mandatory identification of content creators, which includes verification of documents, photographs, and linking of a bank account. This confirms the possibility of establishing the identity of the recipient of the funds.
Regarding the argument about living abroad, the court emphasised that staying in another country in itself does not mean an automatic loss of tax resident status in Ukraine. Changing tax residency and paying taxes abroad requires appropriate documents and evidence.
Thus, the tax authority's decision on additional tax assessments and the application of fines remained in force.
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