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OnlyFans model lost court case to the tax authority: international data exchange proved foreign income of $61 thousand 💸💼
This was reported by the Telegram channel "Sudom po skhemakh" citing case No. 620/7833/26.
10 September 2026 the Chernihiv District Administrative Court dismissed the claim of Antonina Mykhailivna Zazhyttko against the Main Department of the State Tax Service in the Chernihiv region to overturn tax notices-decisions totaling more than half a million hryvnias.
📌 Case circumstances and the STS position
The State Tax Service of Ukraine received information from the competent authority of the United Kingdom of Great Britain and Northern Ireland under the international exchange of tax data. According to the provided documents, A.M. Zazhyttko received income from the British company Fenix International Ltd (owner of the OnlyFans platform) in 2021–2022 for a total amount of 61 166 USD:
• 2021 year — $24 941;
• 2022 year — $36 225.
A declaration of assets and income for those periods was not filed, and personal income tax (PIT) and the military levy were not paid.
As a result of an unscheduled audit, the STS assessed:
• PIT and financial sanctions: 360 907,77 UAH liability + 90 226,94 UAH penalty;
• Military levy and penalty: 30 075,64 UAH liability + 7 518,91 UAH penalty;
• Penalties for failure to file declarations and to respond to a request: 8 680 UAH.
The total amount of tax debt amounted to 497 557,50 UAH, in connection with which the tax authorities also decided to seize the plaintiff's property as tax collateral.
⚖️ Plaintiff's arguments
Antonina Mykhailivna Zazhyttko applied to the court demanding the cancellation of all decisions and the tax demand, relying on the following arguments:
1. The STS letter with data from the British authorities is not a primary document within the meaning of the Tax Code of Ukraine, and therefore does not prove receipt of income.
2. She was not informed of the inspection, which caused her to lose the opportunity to provide explanations.
At the same time, the plaintiff did not dispute in court the fact of registering an account and creating content on OnlyFans, and did not provide evidence of tax payments in the United Kingdom.
🏛️ Court conclusions
The Chernihiv District Administrative Court, presided over by Judge D.O. Vynohradova, fully supported the position of the tax authority:
• Official status of the data: Information received under the Convention for the Elimination of Double Taxation and the Convention on Mutual Administrative Assistance in Tax Matters constitutes proper tax information and is a legitimate basis for the STS conclusions.
• Proper notification: The tax authority sent correspondence to the official address. Non-receipt of letters by the taxpayer does not exempt them from negative consequences or from the duty to monitor their mail.
• Lawfulness of the seizure: Since the tax assessments were recognized as lawful, the claim for payment of the debt and the seizure of property as collateral are also lawful.
The court dismissed A.M. Zazhyttko's claim in full.
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