OnlyFans, Taxes and On‑Site Audits: How WINNER Protects Models and Individuals

According to the State Tax Service, Ukrainians who earned income from posting content on OnlyFans in 2020–2022 already “owe” the state 384.7 million UAH in taxes. The tax authorities actively use information exchange with foreign agencies, receive data from Fenix International Ltd and massively assess additional personal income tax and military levy. For models and other creators this means audit reports, tax notices‑decisions, risks of account freezes and even criminal proceedings for tax evasion.

At the same time, the system still thinks in terms of a “classic” taxpayer: salary or sole proprietor, hryvnia accounts in a Ukrainian bank, straightforward contracts. The reality of OnlyFans is a foreign platform, foreign currency, payment services, cryptocurrency, expenses abroad and P2P transactions, where the state sees only part of the operations. In response, the tax service often chooses the most primitive approach: it takes the total from a foreign statement and calculates taxes “to the maximum” without analysing what the particular taxpayer actually received.

Our case: an OnlyFans model vs. the tax authorities
WINNER Law Firm specialises in tax and administrative disputes, including for individuals, entrepreneurs, creators and business owners. Our practice includes a case of an OnlyFans model to whom the STS assessed substantial additional personal income tax and military levy, relying solely on information from a foreign tax authority and aggregated payout figures.

We built the defence on three key pillars: first, the lack of proper evidence that the entire stated amount was in fact received by the client as taxable income; second, significant violations of the audit procedure and the way its results were recorded; third, incorrect application of the Tax Code provisions to foreign income and limitation periods for additional assessments. The court agreed with WINNER’s position and cancelled the tax notices‑decisions, fully removing additional assessments and penalties from the client.

This case shows that even in high‑profile topics such as OnlyFans, a taxpayer can defend themselves if they work with lawyers who understand both tax practice and the specifics of the new digital economy.

From criminal cases to on‑site audits: what WINNER does
Today the tax authorities aggressively use the full toolkit of pressure: documentary and on‑site audits, fines, blocking of activities, and in complex cases criminal proceedings under tax articles. A typical story starts with a “standard” request or warning letter and ends with several years of additional assessments, frozen accounts, interrogation summons and the risk of criminal liability.

WINNER Law Firm provides a full cycle of protection for businesses, sole proprietors and individuals: from consultations and risk analysis to audit support, challenging tax decisions in administrative and court procedures, and responding to searches, interrogations and other investigative actions. We help clients prepare for audits, minimise penalties, defend their rights in court and, where necessary, properly structure income from foreign platforms to reduce future risks.

If you have received an audit report, a tax notice‑decision, a summons for interrogation or an information request regarding income from OnlyFans or other foreign sources, you should not face it alone. Contact WINNER Law Firm to build a timely strategy from the “first letter” to the final court decision and protect yourself from penalties, account blocks and criminal pressure.

Maksym Bahniuk, Head of Tax and Customs Law Practice, and Yevhenii Murchenko, Head of Criminal Law and Procedure Practice at WINNER Law Firm.