Volyn court invalidates tax assessments against woman over OnlyFans

Court rejects tax authorities' claims regarding OnlyFans income

The Volyn District Administrative Court issued a ruling in favour of the taxpayer in a dispute with the State Tax Service. The case concerned income that, according to the tax authority, the woman received in 2022 from the British company Fenix International Ltd, the operator of the OnlyFans service.

This became known from the court's decision dated 2 October 2026 in case No. 140/9102/26.

Causes of the dispute

The Main Directorate of the State Tax Service in Volyn Oblast assessed additional personal income tax and military levy against Ruslana Svistun, additionally applying penalty sanctions. The basis for these actions was material obtained through international exchange of tax information, which indicated possible income from creating content on the aforementioned platform.

Deficiencies in the tax authority's work

During the hearing, the court established that the tax service had committed a number of deficiencies in its work:

• Only general analytical information from a letter from the State Tax Service of Ukraine was used as evidence. Primary documents, such as bank statements or data on electronic wallets, were not provided.
• The tax authority failed to prove that the plaintiff had undergone verification on the platform, actually created content, and received financial funds.
• To recalculate income in hryvnia, the State Tax Service applied the exchange rate on the last day of the year, instead of the rate at the time of each specific transaction.

Outcome of the court proceedings

Due to the absence of proper and admissible evidence of income receipt, the court fully granted Ruslana Svistun's claim. It was also ordered that court costs be recovered in her favour from the State Tax Service's budget allocations.

It is worth noting that this decision concerns only the specific tax dispute. It does not mean an automatic exemption for all content creators on OnlyFans from the obligation to pay taxes on such income.