Despite 215 members of the media waiting for Cristiano Ronaldo to speak to them after his court testimony, the Portuguese played declined to make a statement and distributed a press release instead.
The Portuguese left court shortly after 13.00 CET and was in no mood to speak to the assembled press.
Here, we detail Ronaldo’s statement that was released on Monday afternoon following his court appearance:
During the hearing, Cristiano Ronaldo said before Judge Monica Gomez Ferrer that he has never hidden income in his tax returns.
“The Spanish Treasury knows in detail all my income, because we have given them, I have never concealed anything, nor did I intend to evade taxes,” he said.
“I always do my tax returns voluntarily, because I think we all have to declare and pay taxes according to our income.
“Those who know me know what I ask my advisors: to have everything up to date and properly paid, because I do not want problems.”
The player said before the court that he has never had tax problems in the countries where he has resided and he assured that, contrary to the argument put forward by the Public Prosecutor in his complaint, the transfer of his image rights to a company he owned was not when coming to Spain in 2010, but was carried out in 2004 at the request of English lawyers.
“When I signed for Real Madrid, I did not create a special structure to manage my image rights, but I kept the one that managed them when I was in England,” noted Ronaldo.
The lawyers recommended by Manchester United created it in 2004, long before he thought to come to Spain. The structure was the one that was usual in England, was verified by the English Treasury and ratified that it was legal and legitimate.
Cristiano’s image management structure remained the same between 2010-2014 as it was between 2009-2009, with only two differences: the English entity was abolished because he no longer resided there and that all of the image rights were collected personally by Cristiano while he was a resident in Spain, to pay the Spanish taxes.
Neither of these changes was intended to circumvent tax payments or conceal income. On the contrary, by collecting royalties for the transfer of his image, greater transparency was obtained and the Spanish Treasury was assured that it would receive the taxes that were legitimately due to it.
Since 2015 Cristiano Ronaldo has ceded his image rights to an independent third party paying his taxes for him. He is currently listed in Spain for his taxes, being one of the largest earners in the country.
According to the player’s advisers, the Office of the Prosecutor maintains two differences with the statements presented:
I. The player qualified the incomes received as income from movable capital, quantifying the part obtained in Spain according to the criteria that the English administration set when he was resident in that country. The Treasury Inspectorate acknowledges that, if the qualification made by the player were correct, he would have paid in Spain more than he was entitled to pay; but they consider that the amounts are not derived from the transfer of the player’s image but from their economic activity, which leads them to consider obtaining in Spain a much higher amount.
The advisers of Cristiano Ronaldo consider that the rating proposed by the Inspection is erroneous, Being contrary to the verdict of the law applicable to the impatriates – as was the case of Cristiano Ronaldo in the period 2010 to 2014 – to the jurisprudence and the existing administrative doctrine in this respect. Therefore, they trust that the judges will dismiss this complaint as there is no defrauded fee.
II. The time when charges for image rights for the years 2011, 2012 and 2013 had to be declared. The player declared in one go, in fiscal year 2014, all image revenue for fiscal years 2011, 2012 , 2013 and 2014 because it is this year when they are paid by the society that had been receiving them since 2004. The Inspectorate of Finance believes that they had to declare year after year.
In the absence of any concealment, since all amounts were perceived personally by the player and were declared by him, the difference of criterion is limited to a mere temporary difference. In economic terms this difference has favored the Spanish Treasury as a consequence of the increase in tax rates (higher in 2014 than in 2010 and 2011), and the evolution of the exchange rate (with a strong revaluation of the dollar, a currency in which a significant part of the rights was collected). If the annuities had been declared each year, the amount to be paid would have been lower.