Cristiano Ronaldo is facing a tax probe over £120million of image rights, according to reports in Spain.
The Real Madrid star has been accused of failing to pay the full amount on earnings between 2009 and 2011.
Spanish financial website El Confidencial report that the tax authorities are finalising a case looking into alleged irregularities – with the star said to have diverted money to the British Virgin Islands through shell companies in several countries.
Ronaldo has previously denied any wrongdoing in the case.
The agency that represents him and several other high profile stars – Jorge Mendes’ Gestifute – has released his tax records.
They showed that the Portuguese held offshore earnings of around £175m in offshore earnings in 2015.
But the Spanish taxman is working on an audit that shows Ronaldo paid just £4.8m on image rights between 2009 and 2015.
The taxman has until June 30 to file their complaint before the statue of limitations expires.
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A Gestifute spokesman is reported as saying: “In accordance with the ‘Beckham Act’, which [Ronaldo] was subject to at the time in question, he was only obliged to pay tax on image rights earnings generated in Spain and not on those from abroad.”
However, the spokesman said that the Spanish tax authorities have “different criteria”.
They also state that at no time was there any intention from Ronaldo or his advisers to commit fraud.
The initial allegations against Ronaldo were published by German broadsheet Der Spiegel and Spanish newspaper El Mundo.
The information was revealed by Football Leaks – which has also made the same claims against Jose Mourinho, another Mendes client.