OnlyFans will have to pay UK value added tax (VAT) on the full amount paid by subscribers to content creators, not only its 20% cut of the fees, Europe’s top court said on Tuesday, siding with Britain’s tax authority.

OnlyFans operator Fenix clashed with UK tax authorities after they ordered it to pay VAT on all the money paid by fans between 2017 and 2020, not just the 20% it took from creators for services such as collecting and distributing fees.

The company took its grievance to a UK tribunal which then sought advice from the Court of Justice of the European Union (CJEU), Europe’s highest. The request was made before Britain withdrew from the European Union in 2020.

In its ruling, the Luxembourg–based court said that VAT should be collected on the total amount received by content creators, including the “intermediary services“ charged by the platform.

“Where a taxable person (OnlyFans) provides intermediary services between content creators and subscribers, the value of those services must be taken into account for the purposes of calculating the taxable amount for VAT on the fees charged to subscribers,” the court said in a statement.

The CJEU added that the VAT should be calculated in the same way as if the content creators had supplied the services directly to the subscribers.

The judgment is final, and the UK tribunal now has to examine the case in accordance with it and make its final ruling.