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💸 OnlyFans income under SPS control: Zakarpattia court upheld additional tax assessments against a male blogger
⚖️ The Zakarpattia District Administrative Court issued a ruling in the case brought by content creator and model Herald Zyazyn against the Main Department of the State Tax Service in Zakarpattia region seeking to cancel tax assessment notices. 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" with reference to case No. 260/2843/26.
Notably, in this case the plaintiff is a male model. Usually in court disputes over additional tax assessments for OnlyFans content the decisions of the State Tax Service are challenged by women, but this ruling shows that all content creators are targeted by the tax authority regardless of gender. It is also noteworthy that Herald Zyazyn had previously appeared in another court decision on similar relations with the tax authorities, and now faced additional assessments in this case as well.
🔍 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 tax authorities of the United Kingdom under international data exchange. According to these data, in 2022 Zyazyn received from the UK business entity Fenix International Ltd income for creating content on the OnlyFans platform in the amount of 494 US dollars (under 8 transactions).
Because a tax return for 2022 year was not filed and taxes on foreign income were not paid, the State Tax Service issued tax assessment notices by which it additionally assessed:
• 💰 Personal income tax (PIT) — 3 251,67 UAH (plus a penalty — 325,17 UAH);
• 🛡️ Military levy — 270,97 UAH (plus a penalty — 27,10 UAH);
• ⚠️ Penalty for failure to file a return — 340,00 UAH.
🏛️ Plaintiff's arguments and the court's position
The plaintiff tried to challenge the additional assessments, claiming he did not create content on OnlyFans and did not receive the stated funds. As evidence he provided bank statements from JSC PrivatBank showing no data about such senders. It was also noted that letters from tax authorities are not primary documents.
However, the court sided entirely with the tax service, noting the following:
1. 🌐 International tax information is admissible evidence: Information received from competent foreign authorities through international information exchange conventions is a lawful basis for tax control.
2. 📌 User identification: The verification procedure on the OnlyFans platform excludes accidental attribution of an account to another person, since it requires identity confirmation by official documents.
3. 📉 Burden of proof: The court referred to Supreme Court practice: if a controlling authority provides official data on the existence of foreign income, the taxpayer must refute it with proper evidence and documents, which was not done.
As a result, the court found the tax authorities' actions lawful and the plaintiff's claims unfounded, fully dismissing the claim on 02 October 2026.
💡 Advice from the Telegram channel "Sudom po skhemakh"
• 📝 Declare foreign income on time: All receipts from international platforms (OnlyFans, Twitch, YouTube, Patreon, etc.) are subject to taxation in Ukraine at a rate of 18% PIT and 1,5% military levy regardless of the amount and the author's gender.
• 🌍 International exchange covers past periods: The State Tax Service successfully obtains data from foreign partners (including the United Kingdom) going back several years, so closed or old accounts remain at tax risk.
• 🗂 Bank statements from a single account won't save you: Having statements only from your main bank does not prove the absence of other accounts or e-wallets to which payments from platforms could have been made.
Telegram publication