Court orders Dnipropetrovsk resident to pay 411,000 UAH in taxes on OnlyFans income

The Dnipropetrovsk District Administrative Court concluded the review of case No. 160/22262/26, denying Tetiana Nesterova's claim against the Main Directorate of the State Tax Service in Dnipropetrovsk Oblast. The court upheld the tax assessments, the total amount of which exceeds 410,000 hryvnias. These funds relate to undeclared income received by the plaintiff from the OnlyFans platform.

Data source: international tax information exchange

The decision was issued on 18 September 2026. The document states that Ukrainian tax authorities have the legal right to use information provided by competent authorities of other states for conducting audits and determining taxpayers' tax liabilities.

The State Tax Service obtained information about Nesterova's financial operations from the authorities of the United Kingdom of Great Britain and Northern Ireland. This exchange took place under the bilateral Convention for the Elimination of Double Taxation and the Convention on Mutual Administrative Assistance in Tax Matters.

The British side transmitted personalised data on payments made by Fenix International Ltd (the owner of OnlyFans) to Tetiana Nesterova for the period 2020–2022. Transaction details reveal the scale of the income:

• 2020: 1 transaction for the amount of 499 US dollars;
• 2021: 17 transactions for a total amount of 21,573 US dollars;
• 2022: 19 transactions for the amount of 28,631 US dollars.

The total amount of payments over three years was 50,703 US dollars, which is equivalent to approximately 1.65 million hryvnias.

Plaintiff's arguments and the court's position

Tetiana Nesterova attempted to challenge four tax notification decisions. Among her main arguments, she stated that she had not received audit orders or requests from the State Tax Service because she was abroad. The plaintiff also claimed that the data received from Britain are not primary documents and challenged the National Bank of Ukraine exchange rate applied by the tax service (as of 31 December of the respective year).

The court rejected these objections. Regarding the service of documents, the court noted that the State Tax Service sent correspondence to the official tax address. The return of a letter with the mark "due to expiration of storage period" is considered proper service. At the same time, the taxpayer is obliged to notify the tax service of any change of residence.

Regarding the evidentiary base, the court recognised international tax information as admissible evidence. The transmitted information contained Nesterova's full name, taxpayer registration number, date of birth, and address. Since the plaintiff herself did not provide bank statements or other primary documents that would refute this data, the State Tax Service had the right to form conclusions based on information obtained within the framework of international exchange.

Amount of fines and taxes

The court also confirmed the legality of converting income at the National Bank of Ukraine exchange rate as of 31 December of the reporting year, as the taxpayer did not provide documents with the exact dates of each transaction.

According to the decision, the total amount of liabilities that remained in force is over 410,000 hryvnias. The breakdown of payments is as follows:

• 371,154.89 UAH — personal income tax together with penalty sanctions;
• 30,929.57 UAH — military levy with corresponding penalty sanctions;
• 8,000 UAH — fine for failure to provide documents upon request from the State Tax Service;
• 1,020 UAH — fine for failure to submit declarations on property status and income for three years.