Image rights

The prosecutor said that after Ronaldo signed a contract to join 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 sole 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 season scoring two goals in a 4-1 victory over Juventus in the Champions League final - his fourth triumph in the tournament.

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.

Reuters