Attorney
Lawyer, expert in tax law, protection of clients' interests in tax disputes, provision of professional advice on tax issues, appeal of unlawful decisions of tax authorities, optimization of tax burden.
Case: Challenging tax notices-decisions: client defense in a dispute with the State Tax Service regarding OnlyFans income
Service: OnlyFans Lawyer
A female client contacted Prikhodko & Partners Law Firm after the Main Directorate of the State Tax Service of Ukraine in Kyiv conducted an unscheduled documentary desk audit and assessed substantial tax liabilities against her.
The audit was initiated based on information received by the State Tax Service from the competent authority of the United Kingdom regarding income allegedly earned by the client from the British company Fenix International Ltd for creating content on the OnlyFans platform.
Following the audit, the tax authority determined that the client had received more than UAH 3.9 million in income, which, according to the State Tax Service, was subject to taxation in Ukraine. As a result, the authority assessed additional personal income tax liabilities exceeding UAH 700,000 and almost UAH 60,000 in military levy, along with additional financial penalties.
What We Did
We conducted a comprehensive analysis of the audit materials, international tax information, the grounds for determining the client’s income, and the procedure followed during the tax audit. Our primary objective was not merely to challenge the amount assessed by the State Tax Service but to determine whether the tax authority had actually proven that the client received taxable income, established its amount and the period in which it was received, and demonstrated that the relevant accounts belonged to the client.
In court, we argued that the mere existence of information received from a foreign competent authority does not release the State Tax Service from its obligation to prove all circumstances necessary to establish a tax liability.
Particular attention was paid to personal identification. The tax authority was required to demonstrate that the information concerning the OnlyFans accounts and the transactions mentioned in the international tax information actually related to our client.
Result
The Kyiv District Administrative Court upheld the claim and canceled the contested tax assessment notices.
The tax authority disagreed with the decision and filed an appeal. We continued representing the client’s interests before the appellate court, emphasizing the insufficiency of evidence that could conclusively establish a connection between the OnlyFans activities and our client.
On October 5, 2026, the Sixth Administrative Court of Appeal issued a ruling declaring four key tax assessment notices unlawful and canceling them, including those imposing personal income tax and military levy liabilities, as well as penalties for failing to submit documents and a tax return.
The appellate court specifically noted that the case materials did not contain sufficient evidence conclusively establishing that the OnlyFans accounts belonged to the client.
Conclusion
As a result of comprehensive legal representation throughout the dispute, the client obtained judicial protection against the principal additional tax assessments, and the personal income tax and military levy liabilities imposed by the State Tax Service were canceled.
This case demonstrates the importance of a comprehensive analysis of tax audits: from the legality of the audit procedure and the content of international tax information to the relevance and admissibility of evidence, taxpayer identification, and actual proof of income receipt.
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