Court cancels nearly UAH 674,000 in tax assessments against Odesa-based OnlyFans model

Tax authority assessed over UAH 674,000 for OnlyFans content

The Main Directorate of the State Tax Service in Odesa Oblast conducted an unscheduled documentary audit concerning citizen Nadiya Shakmatova. The grounds for the audit were information received from the British tax authority, HMRC. According to this information, in 2023, the woman allegedly received over US$59,800 from the British company Fenix International Ltd for creating content on the OnlyFans platform.

Because Shakmatova did not file an income declaration for the relevant year, the regulatory body assessed her with a significant sum of money. The total amount of tax claims was nearly UAH 674,273. The structure of the assessments included:

• UAH 409,177.56 in personal income tax and UAH 204,588.78 in fines;
• UAH 34,098.13 in military levy and UAH 17,049.07 in fines;
• additional fines for failure to file a declaration, failure to provide documents, and failure to respond to requests — the total amount exceeded UAH 9,000.

Court found procedural violations and lack of evidence

Considering case No. 420/21858/26, the Odesa District Administrative Court issued a ruling in favour of the taxpayer on 23 October 2026. The court established a number of violations in the actions of the tax service.

First, the regulatory body did not adhere to the proper procedure for notifying about the audit. The order and the corresponding notification were sent by post, but the shipment was returned to the sender due to a violation of storage deadlines. Thus, Nadiya Shakmatova was not properly notified about the conduct of the audit.

Second, the court found the tax authority's evidentiary base insufficient. The information received from British competent authorities alone was not enough to confirm the fact of receiving money from Fenix International Ltd. The audit materials lacked bank statements, data on specific payment transactions, as well as evidence of Shakmatova's registration or verification on the OnlyFans platform or her direct creation of content.

In addition, the court noted an error in the calculations: tax officials used the exchange rate on the last day of 2023 instead of the rates on the actual dates of fund receipt to convert income into hryvnia.

Full satisfaction of the claim and reimbursement of court costs

The Odesa District Administrative Court fully satisfied Nadiya Shakmatova's claim. All five tax notification decisions, which provided for the recovery of the aforementioned amounts, were deemed unlawful and cancelled.

Additionally, the court ordered the recovery of UAH 5,394.19 in court costs in favour of the plaintiff at the expense of the tax service's budget allocations.