Court Overturned Tax Reassessments on OnlyFans Income: Tax Authorities Failed to Provide Evidence

Volynska Circuit Administrative Court sided with the taxpayer in the dispute with the State Tax Service regarding taxation of funds received in 2022 year from the British company Fenix International Ltd, which owns the OnlyFans platform.

This was reported by the Telegram channel «Judging Schemes» with reference to the court decision from 2 October 2026 of the year in case No. 140/9102/26.

The Main Department of the State Tax Service in Volyn region assessed personal income tax and military tax on Ruslana Svystun, and also applied penalties. The basis were materials of international tax information exchange about allegedly received income from content creation on OnlyFans.

However, during the court proceedings it became clear that the tax authorities used only general analytical information from a letter of the State Tax Service of Ukraine, without supporting it with primary documents. In particular, the controlling body did not provide bank statements or data on funds movement in electronic wallets.

Also, the State Tax Service did not prove that the claimant passed verification on the platform, created content, and actually received the corresponding funds.

Separately, the court established that the tax authorities improperly applied the exchange rate as of the last day of the year instead of the rate on the dates of each operation.

Due to the lack of proper and admissible evidence, the court fully satisfied Ruslana Svistun’s claim, canceled tax assessments and penalties. Also, court costs were recovered in favor of the claimant at the expense of the tax service's budgetary allocations.