Chernivtsi court confirms over UAH 550,000 in back taxes for OnlyFans model

Court ruling on OnlyFans income

The Chernivtsi District Administrative Court concluded the review of case No. 600/2565/26-a, in which model Anastasiia Ipatii is the plaintiff. She challenged tax notification decisions issued by the Main Directorate of the State Tax Service in Chernivtsi Oblast. The court dismissed the claim, effectively confirming the legality of the back taxes amounting to over 550,000 hryvnias.

Grounds for the audit

The tax service initiated the audit, conducting a documentary, unscheduled, non-visit inspection. Its purpose was to determine the timeliness and completeness of tax payments on income received by a Ukrainian resident from abroad in 2023. The basis for the audit was information transmitted by competent authorities of the United Kingdom within the framework of international exchange of tax data.

Amount of untaxed income

During the audit, it was established that Anastasiia Ipatii received funds through the British company Fenix International Ltd, which is the operator of the OnlyFans platform. As a result of the analysis of 50 transactions, total income of US$50,124 was recorded. In hryvnia equivalent, this amount is UAH 1,903,829.36. Meanwhile, the property status and income declaration for 2023 was not submitted, and the corresponding taxes and military levy were not paid.

Amount of back taxes and fines

As a result of the audit, the tax authority assessed the following amounts:

• Personal Income Tax (PIT): the main liability is UAH 342,689.36, penalty sanctions — UAH 171,344.68. Total amount — UAH 514,034.04.
• Military levy: main liability — UAH 28,557.44, penalty sanctions — UAH 14,278.72. Total amount — UAH 42,836.16.
• Fine for non-submission of the declaration: UAH 340.00.

Court's reasoning

The court ruling noted several key points. First, the court recognised as admissible evidence obtained from foreign tax authorities on the basis of international conventions. Such data can be used for conducting audits and assessing back taxes.

Second, the court emphasised that receiving funds from content monetisation is classified as foreign income of a Ukrainian resident. Such income is subject to mandatory declaration and taxation at rates of: 18% for PIT and 1.5% for the military levy.

Third, the court found the claim unfounded, as the plaintiff failed to refute the fact of receiving funds and did not provide evidence of tax payments in the country of origin of the income.