Soccer star Cristiano Ronaldo denied on Tuesday ever hiding any income from the taxman or committing any tax fraud in Spain, after prosecutors filed a lawsuit accusing him of defrauding tax authorities of 14.7 million euros ($16.5 million).
The prosecutor's office said the Real Madrid forward had knowingly used a business structure created in 2010 to allegedly hide his image rights income in Spain between 2011 and 2014.
This involved a "voluntary" failure to comply with his tax obligations in Spain, the statement from the office's economic crimes section said. The four counts of tax fraud were based on a report from Spain's tax agency, it said in a statement.
Ronaldo denied the accusations through his representatives late on Tuesday.
"There is no tax evasion scheme ... There has never been any hiding nor any intention to hide anything," Gestifute, the agency representing the player, said in a statement.
Gestifute said it would publish documents to show the Portuguese player had not created such a structure and had instead used firms he had owned since his time at Manchester United that both British and Spanish tax authorities had been aware of.
The agency also said the case could relate to different interpretations between the British and Spanish tax systems over where to declare some revenues but would in any case not constitute fraud.
Ronaldo, who led Real Madrid to their 12th European Cup earlier this month, is the latest in a long line of soccer players in Spain - among them Barcelona's Lionel Messi and Neymar - to be caught up in cases over tax or transfers.
Between 2005 and 2010, foreign players in Spain were protected under the so-called "Beckham law" allowing them to curb their taxes. But as the financial crisis bit deeper, that exemption was lifted, paving the way for the cases.
The prosecutor's office alleges that Ronaldo had defrauded the tax authorities of 1.4 million euros in 2011, 1.7 million euros in 2012, 3.2 million euros in 2013 and 8.5 million euros in 2014.
The prosecutor said that after Ronaldo signed a contract to join Real Madrid in December 2008 he ceded his image rights to a company called Tollin Associates Ltd, domiciled in the British Virgin Islands and in which he was the only stakeholder.
Tollin Associates then ceded his image rights to a company in Ireland called Multisports&Image Management Ltd which was responsible for managing them. Tollin Associates itself had no business activity, the statement said.
"Ceding image rights to (Tollin Associates) was completely unnecessary and its only purpose was to create a screen to conceal the totality of his image rights income from the Spanish tax authorities," the statement said.
The prosecutor's office filed the lawsuit against Ronaldo on Tuesday to a court in the Madrid district of Pozuelo de Alarcon.
Ronaldo finished the soccer season scoring two goals in a 4-1 victory over Juventus in the Champions League final to become the tournament's top scorer with a total of 12 goals.
In May, Spain's Supreme Court rejected an appeal by Messi and stood by a Catalan regional court's 21-month prison sentence for defrauding authorities of 4.1 million euros on image rights. He is unlikely to go to prison as under Spanish law sentences under two years can be served under probation.
Spain's High Court last month cleared Neymar of fraud but he still faces a corruption trial in Spain in connection with the value of his 2013 transfer from Santos to Barcelona. He has denied wrongdoing.