OnlyFans and taxes: a model from the Odesa region has lost her appeal over more than 1.7 million hryvnias

This has been reported by the Telegram channel "Sudom po shemah".

The gist of the case

According to the tax authorities, in 2022 the woman received almost $200,000 from a British company — the platform’s owner. These funds were not declared, after which she was charged additional personal income tax, a military levy and fines.

Arguments of the parties

The claimant attempted to challenge the decision, arguing that the audit was allegedly unlawful and that the data from foreign authorities was inadmissible.

However, the court rejected these arguments.

The court’s position

The judges emphasised:

• the international exchange of tax information constitutes a lawful basis for audits;
• the platform’s data is linked to verified accounts, which makes accidental identification impossible;
• ignoring postal notifications does not exempt one from liability.

How much will have to be paid

The court upheld the assessment:

• over 1.3 million UAH in personal income tax;
• approximately 328,000 UAH in fines;
• around 137,000 UAH in military tax and penalties;
• additional administrative fines.

In total — over 1.7 million UAH.

The decision has come into force

Tax authorities v OnlyFans: a model from the Odesa region lost her appeal over 1.7 million hryvnias

The Fifth Administrative Court of Appeal in Odesa upheld the decision to impose additional tax liabilities on a resident of the Odesa region who received income from the OnlyFans platform but failed to declare it.

This was reported by the Telegram channel ‘Sudom po shemah’ with reference to case No. 420/19498/25.

UK data on income of $199,000

The court proceedings concerned a claim by Maria Borisovna Sukhanova against the Main Directorate of the State Tax Service in the Odessa region. Tax officials conducted a documentary audit based on information received from the competent authorities of the United Kingdom of Great Britain and Northern Ireland.

According to materials from the international exchange of tax information, in 2022 Sukhanova received income from the British entity ‘Fenix International Ltd’ (owner of OnlyFans) for content creation amounting to US$199,545. As these funds were not declared in her annual tax return, the tax authority charged the claimant personal income tax, a military levy and penalties.

The model’s position: the audit was unlawful

In her appeal, Maria Borisovna Sukhanova insisted that the tax audit had been conducted in breach of procedure, and that the data from the British authorities did not constitute ‘primary documents’ within the meaning of Ukrainian law. She also claimed that she had not received any letters from the tax authorities, and therefore the audit had been ordered unlawfully.

However, the panel of judges at the Fifth Administrative Court of Appeal rejected these arguments.

Why the court sided with the state

In its ruling of 20 April 2026, the court reached the following conclusions:

1. International exchange: The State Tax Service of Ukraine has a legal right to receive data from foreign authorities within the framework of international conventions, and this information constitutes a valid basis for tax control.

2. Digital verification: The court noted that the owner of the OnlyFans platform provides information on payments only after the user has undergone a voluntary verification procedure (providing passport details and a photo). Consequently, the accidental inclusion of the claimant’s personal data in the reports was ruled out.

3. Responsibility for post: The court confirmed that if a taxpayer fails to collect registered letters from the post office (‘after the retention period has expired’), they are still deemed to have been delivered. The taxpayer is obliged to ensure that correspondence is received at their registered address.

Financial consequences

The Court of Appeal upheld the legality of the tax authority’s decisions of 6 March 2025. Maria Sukhanova will have to pay:

• Over 1.3 million UAH in personal income tax (PIT);

• Around 328,000 UAH in PIT penalties;

• Around 137,000 UAH in military levy and fines;

• Administrative fines for failure to submit documents and declarations.

The total amount payable to the budget for the 2022 tax year will exceed 1.7 million hryvnias. The court ruling came into force upon its adoption.

As a reminder, OnlyFans models have previously won 27 court cases against the tax authorities. A third of the cases were decided in their favour.

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