Economic and legal qualification of digital creators’ income on the OnlyFans platform: service or royalty (through the prism of forensic specialty 13.9)

<jats:p>The article addresses the economic and legal qualification of income received by Ukrainian tax-resident individuals from the OnlyFans platform operated by Fenix International Limited (United Kingdom). Two alternative qualification models are distinguished: remuneration for services versus royalties for the use of copyright objects. Through a systemic analysis of the OnlyFans Terms of Service, the Tax Code of Ukraine, the Law of Ukraine «On Copyright and Related Rights» and the Ukraine–UK Convention for the Avoidance of Double Taxation (1993, as amended by the 2017 Protocol), the author substantiates that part of such payments by their economic nature corresponds to royalty features. The methodological role of forensic specialty 13.9 («Economic studies in intellectual property») is revealed in disaggregating composite platform income into royalty, service, and reimbursement components. A four-component structure of forensic examination under specialty 13.9 is formulated, together with a model for identifying the object of taxation in disputes with tax authorities after the launch of automatic exchange of tax information (CRS) in Ukraine in 2024.</jats:p>