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💸 OnlyFans income under the control of the State Tax Service: Volyn District Court confirmed legality of additional tax assessment for a blogger
⚖️ The Volyn District Administrative Court issued a ruling in the case filed by content creator Viktoriia Illiuk against the Main Department of the State Tax Service in Volyn region seeking cancellation of tax notices-decisions. The court concluded that income received from the international platform OnlyFans through the company Fenix International Ltd is subject to mandatory declaration and taxation in Ukraine.
This was reported by the Telegram channel "Sudom po skhemakh" citing case No. 140/4338/26.
🔍 Essence of the case and the tax authority’s position
The basis for conducting an unscheduled documentary audit was the receipt by the State Tax Service of Ukraine of official information from the UK tax authorities under international data exchange. According to that information, Viktoriia Illiuk in 2023 received from the UK entity Fenix International Ltd income for creating content on the OnlyFans platform in the amount of 46 828 US dollars (equivalent to 1 778 639,83 UAH).
Because the tax declaration for 2023 was not filed and taxes on foreign income were not paid, the State Tax Service issued tax notices-decisions (TNDs), by which it additionally assessed:
• 💰 Personal income tax (PIT) — 320 155,17 UAH (plus penalty sanctions — 32 015,52 UAH);
• 🛡️ Military levy — 26 679,60 UAH (plus penalty sanctions — 2 667,96 UAH);
• ⚠️ Fine for failure to submit a declaration — 340 UAH.
🏛️ Plaintiff’s arguments and the court’s position
Viktoriia Illiuk attempted to challenge the additional assessment, asserting that she had not received the stated funds and that the tables and transaction reports provided by foreign authorities are not “primary documents” in the usual sense under tax law. It was also argued that the tax authority allegedly miscalculated the amounts and did not account for the dates of individual transactions at the exchange rate.
However, the court fully sided with the tax authority, stating the following:
1. 🌐 International information is lawful evidence: Information received from competent foreign authorities under international conventions on exchange of tax information constitutes a full tax basis.
2. 📌 OnlyFans terms of use: According to the platform’s rules, creators are independently required and obliged to report to their jurisdiction’s tax authorities all payments received.
3. 📉 Case law: The court referred to current conclusions of the Supreme Court (including in similar cases) confirming the lawfulness of using data from foreign jurisdictions to monitor residents’ full tax payments in Ukraine.
As a result, the court found the tax authorities’ actions lawful and the plaintiff’s claims unfounded, fully dismissing the lawsuit on 23 September 2026.
💡 Advice from the Telegram channel "Sudom po skhemakh"
• 📝 Declare foreign income on time: All receipts from international platforms (OnlyFans, Twitch, YouTube, Patreon, Apple, Google, etc.) are subject to taxation in Ukraine at a rate of 18% PIT and 1,5% (or 5% during periods of change) military levy. Do not wait for inquiries from the tax authority.
• 🌍 International exchange works: Financial monitoring and automatic exchange of tax information (including CRS and specific requests to partners in agreed jurisdictions) allow the State Tax Service to see Ukrainians’ real income abroad and on closed platforms.
• 🗂 Keep your financial records: If you operate through digital platforms, record every payment, dates of receipt, and amounts in the national currency at the NBU exchange rate on the transaction date to avoid inaccuracies when calculating obligations.
• ⚖️ Administrative and judicial challenges require a strong evidentiary basis: A mere claim of “not receiving copies of primary documents from a foreign company” does not exempt one from tax liability if state authorities have documented the payments.
Telegram publication