Gestifute, the agency that represents Ronaldo and owned by the businessman and agent Jorge Mendes, said in a statement that there was no offshore structure designed to evade taxes.
On Tuesday, the Spanish tax authorities launched a formal complaint against the Real Madrid footballer, accusing him of hiding revenues generated from his image rights.
Prosecutors alleged that between 2011 and 2014 he entered a “business structure” in 2010 in a “conscious” and “voluntary” as a means to intentionally not declare income.
But Gestifute said Ronaldo used the same structure he had in the UK, when he was playing for Manchester United between 2003 and 2009.
The statement said that Ronaldo “never had a tax problem, contrary to what the Spanish Prosecutors insinuates”.
The Spanish authorities accuse the player of hiding part of his income through an offshore company called Tollin, but his representatives said the company was set up by Ronaldo himself while he was playing for Manchester United according to the criteria set by the UK’s Treasury.
Gestifute said Ronaldo’s structure used to pay his image rights taxes was “perfectly legal”, since it was recognised and validated by the UK Treasury.
The agency pointed out the structure is usual among players in England with, it claimed, had 180 players currently operating with it.
“In the case of Cristiano Ronaldo, no income was hidden at all, since the taxpayer settled and paid taxes at the time he collected the income (within the period legally established and previous to any tax inspection).”
It added Ronaldo signed for Real Madrid in 2009 under the Law of Impatriots, legislation in force and prevailing then, and he was taxed only for the incomes that were attributable to Spain.
“No additional tax declaration was done, as the press says. The player declared when Tollin paid him, on 12/31/2014. According to the Spanish law, taxes must be paid when the income is required, and so did the player.
“In conclusion: the declared amount can be discussed, but it is clear that the football player did not try to evade taxes.”
Miles Dean, founding partner of Milestone International Tax Consultants, said, “It’s very difficult to determine whether Ronaldo has done anything untoward.
“He claimed the benefits of the Beckham law, which exempts non-Spanish source income for a period of 6 years - note that this concession has been removed for sportsmen from 2015.”
Dean explained that Tollin is based in the British Virgin Islands (BVI) and licenses the images rights to Multisports Image Management (MIM), an Irish company subject to Irish corporation tax.
“One would therefore argue that the income paid by MIM to the BVI company is outside the scope of Spanish tax. However, if MIM received Spanish source royalties, Ronaldo would be bang to rights."
According to the Forbes rich list published this week, Ronaldo is the 5th highest earning celebrity in the world, with a total £73m banked last year. He was just behind Sean "Diddy" Combs, Beyonce, JK Rowling and Drake.