Zakarpattia court orders OnlyFans male model to pay taxes on foreign income

The Zakarpattia District Administrative Court concluded the review of case No. 260/2843/26, in which content creator and model Gerald Zyazin attempted to challenge a decision by the Main Directorate of the State Tax Service in Zakarpattia Oblast. The judge ruled that income received by the plaintiff from the international platform OnlyFans via the intermediary company Fenix International Ltd must be declared and taxed in Ukraine.

Start of the audit and the amount of back-payments

The grounds for conducting an unscheduled documentary audit were the receipt by the State Tax Service of Ukraine of official information from the tax authorities of the United Kingdom within the framework of international data exchange. According to the data provided, in 2022 Gerald Zyazin received 494 US dollars from the British business entity "Fenix International Ltd" for creating content on the OnlyFans platform. This amount consisted of eight transactions.

Since the tax declaration for 2022 was not submitted and taxes on foreign income were not paid, the tax service issued a decision for back-payment:

• personal income tax (PIT) — 3,251.67 UAH, as well as a fine of 325.17 UAH;
• military levy — 270.97 UAH, as well as a fine of 27.10 UAH;
• fine for failure to submit a declaration — 340.00 UAH.

Plaintiff's arguments

Gerald Zyazin attempted to prove that he did not create content on OnlyFans and did not receive the specified funds. To support his claims, he provided the court with bank statements from JSC "PrivatBank", which did not record any corresponding receipts from a foreign sender. The plaintiff also noted that letters from tax authorities cannot be considered primary documents.

Court's position and final decision

The judge fully supported the position of the tax service. The decision states that international tax information obtained from competent authorities of foreign states through information exchange conventions is admissible evidence for tax control.

In addition, the court emphasised the verification procedure on the OnlyFans platform, which requires identity confirmation via official documents, thereby excluding the possibility that the account accidentally belongs to another person. Citing the practice of the Supreme Court, the judge indicated that if the controlling authority provides official data on the existence of foreign income, it is the taxpayer who is obliged to refute it with proper evidence, which the plaintiff failed to do.

On 2 October 2026, the court recognised the actions of the tax officers as lawful and the claims as unfounded, fully refusing to satisfy the lawsuit.

It is worth noting that Gerald Zyazin had previously featured in another court decision regarding similar relations with tax authorities. This case demonstrates that tax control extends to all content creators regardless of gender, as usually in similar disputes, it is female models who challenge State Tax Service decisions.