The Supreme Court has defined the limits of tax control over income from OnlyFans and other digital platforms

The Cassation Administrative Court of the Supreme Court in case No. 240/22077/25 confirmed that information received from tax authorities of foreign countries is a legitimate source of tax control and may be the basis for conducting an unscheduled documentary audit.

At the same time, the court emphasized: the fact of receiving international tax information itself does not exempt the regulatory authority from the obligation to prove the actual receipt of income by the taxpayer.

The dispute concerned the additional assessment of personal income tax and military duty to a citizen for 2020–2022. The basis was data received from the competent authority of the United Kingdom regarding payments for content posted on the OnlyFans platform.

The tax authority used this information to schedule an unscheduled documentary on-site audit and issue tax notices. However, the Supreme Court noted that foreign data in themselves is not sufficient evidence of either the fact of income receipt, its exact amount, or the correctness of the currency conversion.

Separately, the court emphasized compliance with procedural guarantees: an inspection can be lawful only if the payer is duly served with a copy of the order and a written notification at his tax address. Since the courts of previous instances did not establish these circumstances, the case was sent for a new hearing.

The decision may have important consequences for individuals who receive income through international digital platforms, as it forms a new approach to assessing evidence in tax disputes.