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A union leader at Spain's Hacienda tax authority has questioned how Cristiano Ronaldo's advisers have escaped punishment.
The former Real Madrid forward admitted to four breaches of Spanish tax laws, accepting an €18.8 million fine and two years' suspended prison sentence, sources close to his camp confirmed to ESPN FC.
His long-running tax issues with the Spanish authorities are coming to a close with the 33-year-old having accepted that a network of companies in various countries including Ireland and the British Virgin Islands were used to evade paying €14.7m in taxes due on image rights income he earned between 2011 and 2014.
Carlos Cruzado, president of the union representing technical staff at the Hacienda Ministry (Gestha), said in a statement that the experts who put in place the tax structures found to be illegal should not be totally exempt from prosecution.
"Ronaldo's advisers should not be exempt in any case from possible legal responsibilities," Cruzado said. "They are those with the necessary knowledge to put together the structure of companies.
"The clients -- in this case Ronaldo -- should also be aware of what is going on. The same thing happened when [Lionel] Messi's sentence was confirmed, with the Supreme Court noting that the Tax Agency and prosecutors had not charged the tax advisers as necessary cooperators, and not just [in the case of] the Argentine footballer.
"However it has happened, unfortunately, the punishments for tax crimes are not enough to stamp out evasive practices in football."
Ronaldo is just one of a number of high-profile clients of Portuguese agent Jorge Mendes who have run into similar trouble with Hacienda in recent years. The affairs of Bayern Munich playmaker James Rodriguez, Manchester United manager Jose Mourinho, Monaco forward Radamel Falcao and Paris Saint-Germain winger Angel Di Maria have all been investigated for concerns about image rights income routed through webs of companies in various countries to evade paying taxes due in Spain.
A leaked court transcript from Ronaldo's 90-minute appearance in court in Madrid in July 2017 had him telling judge Monica Gomez Ferrer that "the only thing I know is to play football well. I trust in my advisors, who are the best ... I leave everything in their hands."
In July 2017, Mendes himself gave evidence to judge Gomez Ferrer during a court hearing on Falcao's tax issues.
Ahead of that hearing, Gestifute released a statement saying: "Neither Jorge Mendes nor the company he manages, Gestifute, participate in or provide any type of service directly or indirectly related to financial, tax or legal consultancy for those they represent."
James and Ronaldo have reportedly been represented during recent negotiations with the authorities by Equipo Economico -- a firm headed by former Spanish finance minister Cristobal Montoro.
Ronaldo's tax problems first became public back in December 2016 with reports in El Mundo based on documents discovered via Football Leaks which appeared to show how €150m in image rights income had been channeled through a web of companies established by Mendes and associates.
The Portugal captain currently earns an estimated $93m a year, according to Forbes, with approximately half coming from image rights deals with his many sponsors.
Observers including KPMG's Football Benchmark group argue that having joined Italian side Juventus this summer Ronaldo will now enjoy a more beneficial fiscal situation, paying a flat €100,000 tax on all image rights income earned outside of his new country of residence.
In June 2015, Ronaldo sold his personal image rights up to 2020 to Singapore businessman and Valencia owner Peter Lim. Spanish courts have recently cracked down on tax evasion among leading footballers, who had previously been allowed to use the so-called "Beckham Law" to curb their taxes.
Barcelona forward Messi, and his father, Jorge Messi, were found guilty in July 2016 of three counts of tax fraud relating to image rights income hidden overseas, with Spain's supreme court upholding that verdict in May 2017.
Source: espn.co.uk