Shell Game

Ronaldo, Mourinho and the Paper Trail to the Caribbean

They are at the pinnacle of the sport, but Cristiano Ronaldo and José Mourinho have also proven to be magicians off the pitch as well -- when it comes to their dealings with tax authorities. They both used shell companies in the Caribbean to collect their marketing earnings. By SPIEGEL Staff
 

Photo Gallery: The Shell Game


Football's Dark Side

What would happen if people found out how much teams really pay their professional players, calculated precisely down to the last euro and cent? And what would happen if people knew the size of the commissions earned by agents with each transfer or contract extension? If people were to start to question whether their football heroes are as clean as their marketers like to make them out to be? If you could peer behind the glossy facade of global football and take a closer look at the contracts, bank accounts and the exchange of letters between pro players and their advisers? The whistleblowing platform Football Leaks makes all this possible. They provided DER SPIEGEL with access to around 18.6 million documents -- the biggest leak in the history of professional sports. Together with the investigative network EIC and additional partners, we have explored the inner workings of the multi-billion-euro football business. The first installment in the series delves into the ethics of taxation and the tax tricks used by stars like Cristiano Ronaldo and Mesut Özil.


Messi. Forget Messi. There are people who still consider Messi to be the best in the world. Clueless people. Just because Lionel Messi was football's World Player of the Year five times to Cristiano Ronaldo's three. Just because Messi has won the Champions League four times and Ronaldo three. Just because Messi scored a fantastic 50 league goals in a single season to Ronaldo's phenomenal 48. All of that is true, but what does that matter? Except on the pitch.

But if you are looking for the truth in football on the pitch, then you are, in fact, clueless.

The truth is: Lionel Messi got caught. This summer, he was forced to appear before a district court in Barcelona, where he was slapped with a suspended jail sentence of 21 months for tax fraud. The court also ordered him to pay a fine of 2 million euros because he and his father had avoided paying 4.1 million euros in taxes.

And Ronaldo? Or, more precisely, Mr. Cristiano Ronaldo dos Santos Aveiro, as he is named in his Spanish tax return? At the end of 2014, he discreetly pocketed 63.5 million euros, but apparently didn't pay a single euro in taxes on that money. And he might even get away with it. It might even have been legal. Some 63.5 million euros, before and after taxes, with no court case, no criminal offense and presumably not even a guilty conscience.

So who is the best at football? Ronaldo! Unless, after this article appears, a Spanish tax investigator decides that such a thing can't possibly be legal: two shell companies in the British Virgin Islands; an additional shell company that bunkered Ronaldo's millions for years; an account with a private Swiss bank; a tax declaration that doesn't make any mention of the 63.5 million euros and all of the foreign accounts.

What is it that Ronaldo said about himself? "I'm a smart guy," and "it doesn't matter if you play good or you play bad -- most important is to win." In football, that sentence applies to the pitch, but for top players, it also applies to their bank accounts. Those who haven't yet found the loopholes to reduce their taxes count among the industry's losers.

Indeed, Ronaldo is no exception when it comes to his desire to save on taxes. But his name, like Messi's, is the most famous. He is the most valuable brand and the biggest star. He's the icon, the man who represents the gloss and sordidness of modern football in this story of professionals and their profits. The gloss of a global religion with 1.6 billion followers -- fans consumed with their teams and enchanted by their demigods and by the seemingly supernatural tricks of a player like Ronaldo, which can often only be understood when seen in slow motion. But that sordidness is also named Ronaldo: that only the result counts, the ego, the success. That everything will somehow work out and that nothing really matters, at least as long as tax authorities keep playing along or can be deceived. And as long as the fans, who pay millions to finance these stars, don't find out.

On His Trail

But now the entire world knows. The whistleblowing platform Football Leaks provided DER SPIEGEL with hard drives containing 1.9 terabytes of information -- the biggest trove of data in the history of sports. The dataset is so massive and so significant to so many countries that SPIEGEL shared the material with its partners in the European Investigative Collaborations (EIC) consortium months ago. Since then, 60 journalists from 12 different media organizations in Europe have collaborated in their analysis of the mostly confidential documents.

They reveal how millions of euros earned by Ronaldo in marketing deals were funneled to a shell company in the Caribbean until 2014. He hardly paid any taxes on that money. And as if that wasn't enough, at the end of 2014 he sold his marketing rights for the years 2015 to 2020 for an additional 75 million euros. He quickly collected the money at the end of the 2014 tax year. That, after all, was the last year that he could take advantage of a minimal tax rate in Spain. He apparently paid no taxes on 63.5 million euros of that sum. Now, tax investigators are on his trail.

The documents also expose a second football superstar who plays the concealment game: José Mourinho, an internationally renowned manager who has made successful stops at Porto, Chelsea, Inter Milan and Real Madrid. He has referred to himself as "The Special One" -- and he is undisputedly the most eccentric man sitting on the manager's bench. But he's proven just as eccentric when it comes to his money, keeping it parked not close to home, but in Swiss bank accounts belonging to a Caribbean shell company which is bound together with a foundation in New Zealand, on the other side of the world. Mourinho, the documents show, has since been ordered to pay millions in back taxes.

Other professional footballers also set up repositories for their money in exotic countries. They include Pepe and Ricardo Carvalho, both of whom played on the Portuguese national team that won the European Championship this summer. James Rodríguez, top goal scorer at the World Cup in Brazil, is also on the list. All three play or played for Real Madrid, the world's richest club, where it's not just the player salaries that are extremely big, but also the chutzpah when it comes to taxes. The group of Real players who tried to be more clever than Spanish tax law apparently allows also includes a member of the world-champion German national team: Mesut Özil, who today plays for FC Arsenal in London. He did not funnel his money to a tax haven, but a few months ago he received a tax bill from his previous stop in Spain. Özil has been told to pay 2 million euros in back taxes in addition to an almost 790,000 euro penalty, as the Football Leaks documents show.

The list goes on and on.

Professional football today is show business -- the greatest show on earth. The measure of the biggest stars in this show is money, either in euros or dollars. The transfer sums are growing, as are salaries and advertising revenues. Ronaldo earns 38,181,818 euros a year at Real and his transfer fee -- the amount another team would have to pay to buy him away from Real -- is 1 billion euros. Player salaries have become so astronomical that megalomania has become inherent to the sport. Why share those millions? Why give anything away?

Too Weak for Success

Football Leaks is now exposing the uglier side of these success stories: These stars apparently want to give back as little to society as possible -- none at all if they can get away with it. To do so, they and their advisers walk the tightrope of tax law. Those who don't play this game -- because they still feel a sense of responsibility to society -- are likely seen as being too weak for success.

One sentence stands out in the mountain of data full of greed and megalomania. It was written by Hans Erik Odegaard of Norway in December 2015, after Real Madrid signed his 16-year-old son to the team, hailing him as one of Europe's most talented players. Spanish lawyers had calculated the effect a tax-saving image rights company might have on the player's revenues.

But Odegaard's father had some concerns and wrote: "He will anyway earn a lot of money, so it's also a moral question about how much effort he shall do, trying to save some tax money when other people are struggling much more to pay their bills." The Football Leaks data contains several million documents, and it takes a lot of searching to find one like that.

Martin Odegaard also isn't so easy to find these days. He currently plays mostly on Real's reserve team and has only played for the main team twice. He is reportedly unhappy in Madrid.

2 Million Dollars for Six Hours of Work

So what's a day in the life of Cristiano Ronaldo worth? That's difficult to say, but there are some clues: 1.9 million dollars for six hours and 45 minutes worth of work. That's $4,691 a minute, as revealed in a contract Ronaldo's marketing agents signed with Toyota in June 2013.

Toyota covered Ronaldo's first-class airfare to the filming site where he stood in front of the cameras for three-and-a-half hours before lunch and three hours and 15 minutes afterward -- everything was precisely detailed. The carmaker was then able to use the images in its advertisements for 13 months.

For $1.9 million, however, you won't get the world from Ronaldo. Toyota had merely secured the rights for ads in the Middle East, plus Algeria, Morocco and Afghanistan. The company would have had to pay more for global rights. Honda featured Ronaldo in its advertisements in China at the same time. According to the contract, it brought in an additional 2 million euros for a one-year run-time and a maximum of six hours of work in front of the camera. Additional camera time in China, had it become necessary, would have cost 600,000 euros more -- a bargain by Ronaldo's standards.

Football is global, which makes Ronaldo not only a sports star around the world, but also an advertising star. He earns far more than just his premium salary at Real Madrid. In recent years, he has sold himself from head to toe: to the shampoo brand Clear, to watchmaker TAG Heuer, to the fashion label Armani and to sportswear giant Nike. Nike continually releases new football shoe models bearing the legendary CR7 logo, the seven standing for Ronaldo's jersey number.

If one can believe the contracts, the money pours in: According to the documents, US food giant Herbalife paid more than $16 million over a five-year period. Some 2.25 million euros came from Portugal's Banco Espírito Santo for three years and 300,000 euros from a single television appearance in Rome. One-million-one-hundred-thousand euros came from the airline Emirates for a little more than a year of advertising -- along with 15 first-class tickets to Dubai from anywhere in the world.

For every pair of briefs with the CR7 logo on the waistline, Danish underwear company JBS hands over 13 percent of the revenues. At Nike, it's 5 percent of CR7 shoe sales. The American company brought in 51 million euros in global revenues with CR7-branded apparel between September 2010 and August 2011, with just under 2.6 million euros of that money going to the company that collects Ronaldo's fees. In addition to that, Nike pays a base salary of 1.6 million euros a year, plus the industry-standard premium payments for particularly successful seasons.

When, for example, he became the top scorer in the Spanish league, they paid an additional 250,000 euros.

The State Wants a Cut

In return for this generosity, Ronaldo is subject to Nike's conditions. If he is injured and can't play for more than 90 days, Nike is entitled to cut the base salary in half for the time missed.

The same holds true if Ronaldo plays in more than 20 but fewer than 30 matches a year for his club. And when, in 2014, he traveled to the World Cup despite suffering from a chronic injury and not playing up to his usual standards, he was of course driven by his ambition to always play, to always win and to always be the greatest. But beyond that: If he hadn't played in the tournament, it could have cost him half of his annual earnings from his revenue-sharing agreement with Nike.

Ronaldo, though, almost always delivers. During the past eight years, he has only missed 32 Real matches as a result of injury. And advertising customers continue to pay and pay. This creates the same conundrum for Ronaldo that all of the world's superrich face: What to do with the money that is constantly flooding into their accounts? To be sure, for every euro he earned with his image rights above 15 million per year, he was required to pay 40 cents to his employer Real Madrid. That's what it says in one contract. But he only has to step out of his door for a few hours and say something to the camera -- and someone will wire him a couple hundred thousand or million euros. It's as easy as that. Ultimately, though, it does become complicated. Because the state also wants a cut.

But there are advisers -- specialists for image-rights revenues -- to take care of that, and not just for Ronaldo. The lawyers take care of everything professional football players earn with their name, face, image and autograph. Most of that revenue comes from advertising, but there are other sources too, like the player stickers children collect inside their Panini albums.

It's difficult to reduce taxes on salaries paid by the club. The rules in place are quite clear, the paths for the money obvious and the tax authorities tough. Image rights, though, are an altogether different matter, and tax lawyers have become true artists when it comes to creating the artistic and artificial mazes through which the money flows. Tax authorities are always trying to play catch-up and are often either overwhelmed by the complexity or thwarted by laws in some countries that have been made so friendly to football that the hunt ends before it has truly begun. If things go well for the player, the tax authorities are satisfied with a small payment. And if things go really well, the players pay nothing at all.

The model works more or less like this: Professional salaries fall into the highest tax bracket, which is around 50 percent in many European countries. It can be painful. Revenues generated via image rights, by contrast, aren't taxed at nearly as high a rate, if one sets up the necessary structures. To do so, players transfer their image rights to a company working on their behalf. Fees generated by those rights -- standing in front of the cameras for a granola bar or deodorant brand, for example -- are then paid to that company, which only owes corporate taxes on those earnings, just like any normal company. In Ireland, a popular location for such image-rights firms, the corporate tax rate is only 12.5 percent.
Offshore Structures

The companies that use these stars to peddle their products aren't the only ones paying money to the image firms. The football clubs also pay. Real Madrid, for example, buys a portion of its players' image rights. In exchange, Real pays its players a set fee that is also only taxed at the lower corporate rate.

This is basically how it is done in all the major European leagues. A British court confirmed in 2000 that the practice was aboveboard in the case of Dutch player Dennis Bergkamp. But that doesn't necessarily mean it is legal in other cases as well. Tax authorities aren't fond of this clever division of payments because it denies the state millions in revenues. As such, professional players are placed under investigation time and again for possible tax evasion.

There's a fine line to be drawn, and it's not always clear where it should be. Authorities, for instance, probe whether the image rights that a club purchases from its star players are actually worth the high price paid. Is the club actually able to come close to recouping that investment through, for example, the sale of jerseys or autograph cards? If not, the goal is apparently that of paying a significant portion of a player's salary at the lower corporate rate.

And that would be against the law.

When it comes to superstars, who earn millions for their teams through jersey sales alone, tax authorities dig down elsewhere: Does the image firm have offices and employees or is it purely a shell company? Depending on the national laws in place, that might be considered to be money earned domestically and, as such, subject to the full income tax.

As is so often the case when dealing with money, the greater the profit generated, the greater the risk that something can go wrong. The advantages of using image rights to bring in money are immense, but they come hand in hand with the risk of falling afoul of the tax authorities.

One could simply avoid the practice as young Norwegian player Martin Odegaard apparently did. But if you have an agent like Jorge Mendes, you don't avoid it. You take the plunge.

Big Jorge

Mendes is currently the world's most successful football agent. He represents the most famous players and makes the biggest deals. And apparently the biggest audacity when it comes to tax constructs. He's the man who can make players dizzyingly rich. It's a roll of the dice for the players -- with the help of Caribbean shell companies that are kept concealed. For good reason, one can assume.

Mendes represents Spanish national team goalkeeper David de Gea and the 2014 World Cup Golden Boot winner Rodríguez, of Colombia. He represents half the European champion Portuguese national team including Pepe, André Gomes and Ricardo Carvalho in addition to the young Renato Sanchez, who now plays for Bayern Munich. Most importantly, he represents Cristiano Ronaldo and renowned coach José Mourinho.

A documentary hit the theaters last year about Ronaldo's life ($200,000 was paid for his participation, plus a cut of revenues). The film delves into the death of Ronaldo's father at an early age and Ronaldo talks about how Mendes "became a father" to him: "Jorge is another member of my family."

Naturally "Big Jorge" is also "the best," a title that Mendes has, in fact, been honored with six successive times at the international Globe Soccer Awards for his work as an agent.

Like Ronaldo, Mendes knows what it's like to be poor, but also how good it can feel to have so much money that it no longer fits into the safe at home, as Ronaldo says in the documentary. Both came from families that could give them little beyond the boundless ambition necessary to work their way to money, success and fame.

Mendes achieved his success as a talented salesman. First he flogged videos and then opened a bar before arranging the transfer of one of his regulars, goalkeeper Nuno Espírito Santo, to Deportivo La Coruna. With that, he was an agent, and soon he began dealing in ever-bigger names, in part because he is good at getting others to think as highly of him as he does of himself.

In one scene of the film, he is at dinner with friends and family of Ronaldo, standing in front of the football star. Mendes begins singing his praises: "You're a monster. This is the best in the world, the best footballer in the world … I'm proud to be standing next to a guy like this. … If I didn't know you, I'd ask you for an autograph."

It's easy to understand why footballers adore him, especially given that Mendes is better than others at getting his clients on the big-name teams and landing enormous contracts. By his own account, he was involved in more than half of all transfers made by top Portuguese clubs Benfica Lissabon, Sporting Lissabon and FC Porto from 2001 to 2010. From there, he brokered players to the really big football money in England, Spain and Italy. "Nothing is impossible," Mendes preaches in the Ronaldo film, "nothing, nothing, nothing." He can't even stop saying "nothing," adding "nothing" again and again, like a guru preaching to his disciples. But if nothing is impossible, then what's possible when it comes to the players' taxes? That, namely, has apparently long been part of the package Mendes offers his clients: a tax model that helps top earners avoid taxes to the extent possible. Legally? Illegally? Nothing seems impossible.

Nothing.

A Hideaway for the Mister

José Mourinho is a star coach rather than a star player, but when it comes to what he earns and the airs he puts on, there isn't much of a difference. Mourinho, who today plies his trade at Manchester United, was one of the first professionals for whom Mendes established a tax-saving structure in the Caribbean. He set it up based on the same two principles that guide Mourinho in football: Losing is absolutely unacceptable and any trick that results in victory is allowed.

There's a legendary tale about how Mourinho once got banned from attending a game against Bayern Munich and nonetheless still managed to give instructions to the coaches on the Chelsea bench. The Times of London would later report that he hid in a laundry basket in order to avoid detection as he was smuggled out of the stadium following the match.

The Football Leaks documents now shed light on what the Portuguese manager's legal tricks have brought him. Spanish tax authorities recently fined him 4.4 million euros: more than 3 million euros in back taxes and a 1.1-million-euro penalty on top.

What happened? In 2004, Mourinho switched from Porto to FC Chelsea in London. He had won everything in Porto -- the Portuguese league championship and, surprisingly, even the Champions League. That set the stage for him to get the kind of major money that can't be earned in Portugal. He went to Chelsea, a club where winning European football's crown is not a surprise. It is expected.

Russian oligarch Roman Abramovich had bought the club and he began shopping around for players with no concern for money. There were no limits for Chelsea.

Mourinho, too, earned a hefty salary -- it is said to have been around 5.3 million pounds a year.

That was his regular pay, on which he had to pay full taxes consistent with his top-earner status. But he also received an additional 1.5 million pounds for his image rights from Chelsea from 2004 to 2009.

To be more precise, he didn't get the money directly -- instead, it went to the Caribbean, to Koper Services S.A., a shell company located in the British Virgin Islands (BVI). The letterbox firm resides at Vanterpool Plaza in Road Town on the island of Tortola, which sounds far more glamorous than it actually is.

The plaza is really just a yellow stuccoed, two-story building. The ground floor houses a pharmacy run by a Ms. Vanterpool, while the floor above is rented by a law firm that sets up shell companies. They are located behind the drawn curtains. If any work is actually being done here, it is surely not being done by Koper Services.

Zero Percent

It is basically just a large piggy bank. Up until at least 2013, millions of euros from Mourinho's marketing earnings flowed in. To facilitate this, the coach had transferred his image rights to Koper back in 2004, when he made the switch to Chelsea. The company has been in charge of his marketing ever since, and has raked in the revenues. And these revenues are conveniently taxed at the BVI corporate tax rate of, you got it, zero percent.

But there was still a problem: Renowned brands like Adidas aren't fond of having to transfer fees to tax havens. Should the company be audited, such payments could raise the uncomfortable suspicion that the company was abetting tax evasion or financing some other dubious deals. As such, advertising partners expect a better address than Road Town on the island of Tortola, and in this case, that address was to be found in Ireland. Even before Koper was founded, an Irish tax firm had established a different company in Dublin called Multisports & Image Management (MIM).

Ireland was the kind of European Union country -- the kind of buffer -- needed for companies like Adidas and professional football clubs like Chelsea to be prepared to pay for image rights.

But neither the company's location nor the tax firm were chosen at random. With its low corporate tax rate, Ireland is seen as something of a tax haven within the EU. And the same accounting office in Dublin that founded MIM also worked for "Big Jorge" Mendes, offering its services to Gestifute, the agent's primary company.

Those interested in using Mourinho for marketing purposes had to pay a fee to MIM in Ireland -- and who cared what happened to the money after that? The Football Leaks documents show that MIM received a small commission: Initially it was 6.5 percent before dropping to 4 percent in 2010. A second Ireland-based company, called Polaris, got involved later -- the only organization in the network that had real personnel and did real work. It landed advertising jobs for Mourinho and when it succeeded, it also usually took a 20 percent commission.

And taxes? MIM and Polaris had to pay the Irish corporate tax rate of 12.5 percent on any profits they generated, but the money they received in commissions was just a tiny portion of the overall sum. The rest of the money brought in by Mourinho through advertising -- minus the commissions for MIM and Polaris -- was sent to the British Virgin Islands where no taxes at all were due.

So far, so rich. How, though, would Mourinho one day be able to extract his money from the tax haven piggy bank? It wasn't an easy problem to solve, particularly given that nobody was supposed to learn that the shell company was Mourinho's de facto cash repository. The documents make it clear that his tax advisers were apparently concerned that the entire structure could be revealed as a potential façade for a tax evasion scheme if it became known that Mourinho's money ended up with Koper.

The Trail to New Zealand

Koper's beneficiaries were thus kept well hidden. Straw men stood behind the Caribbean company. And who was hiding behind them? A foundation in far-away New Zealand. The documents indicate that it was founded by Mourinho in 2008. But he wasn't the beneficiary of the foundation.

It would be difficult for the scavenger hunt to lead further away from Mourinho than New Zealand.

Compared with his childish game of hide-and-seek in the laundry basket, it was quite a masterful effort at invisibility. But who in New Zealand? The foundation is called Kaitaia Trust, but Mourinho's name is not listed in the commercial register. The hunt, in other words, isn't over.

The search only ends with the trust's certificate of incorporation, which is also part of the Football Leaks documents: The foundation's beneficiaries according to the certificate are Mourinho's "spouse for the time being and his children." A further document in the data hints at who the millions held by Koper belong to. Koper account statements from Dec. 31, 2013, indicate that the firm owes José Mourinho 11,979,657 euros, the document notes. Owes? That was apparently the trick: Mourinho entrusted his marketing revenues -- more than 11 million euros -- to Koper. It stayed in the family, within his reach -- essentially untouched in Koper accounts in Switzerland.

Things only became particularly uncomfortable for Mourinho after he transferred to Real Madrid in 2010 and then came back for another stint at Chelsea in mid-2013. In July 2014, Spanish authorities began digging into the years Mourinho spent in Madrid and into his network of companies. Though the club had consistently withheld 10 percent of each payment to Koper and forwarded it on to the tax office, most of the football manager's other marketing partners sent their payments to Ireland without withholding anything at all. From there, Mourinho's money -- minus the standard commissions owed to MIM and Polaris -- was sent to the zero-tax paradise of the British Virgin Islands.

The football manager never included his image-rights revenues in his Spanish tax declaration. As early as June 2013, Julio Senn, partner at the tax law firm Senn Ferrero, began sensing that things wouldn't end well. Senn, who was once director general of Real Madrid and is today the most sought after attorney for football players with tax problems in Spain, had spoken with a co-worker who had been involved in Lionel Messi's tax case. The Barcelona star had based his image rights company in Belize and Uruguay. Senn then wrote to a tax expert named Carlos Osório de Castro, who advised Mendes, the agent. It looked as though Spanish tax officials had settled upon a strategy. Only in cases where the image-rights companies belonging to football players had real personnel and real offices were they left alone. Otherwise, Senn wrote, revenues were being seen as part of a player's normal salary. And had to be taxed as such. For Mendes' clients, it was terrible news.

Extremely Nervous

Senn was initially concerned about Mourinho, who apparently hadn't registered his foreign assets in 2012 even though it was required in Spain. In September 2014, the attorney was hoping that Mourinho would at least manage to avoid criminal proceedings. Mourinho was prepared to pay "whatever it takes" to avoid such a fiasco, Senn wrote in an email. That, according to a lawyer colleague of his, was the best approach; he believed that Mourinho would lose in the case of a confrontation, and not just him -- "we all would." Mendes, he noted, was extremely nervous.

That was understandable considering that most of his clients used a similar tax model, one in which an offshore company received revenues from image rights. If one adds up the revenues of his most important clients that have ended up in the Caribbean until today, the total is at least 180 million euros. Internally, Senn -- who was, as of 2014, charged with extricating Mendes's players and Mourinho from the difficulties they were in -- didn't hide how he felt about the Mendes model. In an email to Mendes' tax expert Osório de Castro, he wrote: "Don't forget that the structure that all of Jorge's clients have isn't the most appropriate for people who live in Spain." The Mendes tax expert had served as an adviser for the model. Senn complained that Osório de Castro had been told many times that the tax construct for image rights was unsuitable.

Senn was most explicit when it came to the acute difficulties facing Portuguese national team player Fábio Coentrao. As was typical of Mendes clients, he also had a shell company in the Caribbean. "Gentlemen," Senn wrote, "the structure you have set up is a serious problem for the player."

It was also a problem for Mendes himself. "Let's hope that they (eds. note: tax officials) don't view Jorge's company structure in Ireland as a necessary aid for the players to avoid paying taxes in Spain," Senn wrote. Regarding Coentrao, he wrote: "It could be that circumstances that are less problematic than those we are defending against the tax authorities are seen as tax violations."

Senn was all the more relieved -- and likely surprised -- when he was able to report on June 17, 2015 following negotiations with the tax officials that it looked like Mourinho would get off easy. He would be spared criminal proceedings and a public trial. He would only have to pay.

Koper would even be allowed to write off a few costs -- and there was even a reduction for the year 2013 because Mourinho had moved from Spain to England that summer. Given how worrisome the situation had initially been, the result was quite satisfactory, Senn rejoiced.

Confirmation from Spanish tax officials arrived on June 30, 2015 -- and indeed, everything had turned out well. The officials made it clear that Mourinho should have declared the millions he made from marketing each year and paid taxes on the sum. The tax authority determined that all of the money parked with Koper belonged to him. The state demanded a total of 5.8 million euros: 3.3 million euros in back taxes for his image rights and a 1.1-million-euro penalty.

Mourinho has since paid that sum. He was also faced with an additional 880,000 euros in back taxes and a 550,000-euro penalty for another tax matter. But Senn has filed an appeal against this portion of the ruling. Now that there were no criminal charges or an embarrassing trial to fear, he sought to avoid the remainder of the payment by way of a formality. Tax officials, he argued, took 373 days for their investigation, but only 365 days, one year, were allowed. Mourinho had managed to avoid a war with the authorities, but he is happy to engage in a skirmish. When it comes to ambition and the desire to avoid losing at all costs, "Mister" -- as his attorneys referred to him in internal mails -- can hardly be beat.

Except by one.

Moneyed Footballer of the Year

There are many piggy banks in the Caribbean. The one belonging to Fábio Coentrao, based in Panama, is called Rodinn. Ricardo Carvalho's is called Alda Ventures and is in the British Virgin Islands. Pepe's Weltex Capital is likewise in BVI as is Kenalton Asset, belonging to James Rodríguez. All of them are millionaires, all of them are current or former Real players and all are Mendes clients. But according to the documents, none of these piggy banks were ever as crammed full of money as the one called Tollin Associates. Tollin belonged to Cristiano Ronaldo. Those who went looking for it before it was suddenly dissolved in early 2015 could stop their search in front of the same building where Mourinho's savings were parked: on Vanterpool Plaza in Road Town on the British Virgin Islands, above the pharmacy belonging to Ms. Vanterpool.

Mendes' advisers' biggest fear was that Spanish tax investigators, on the search for Ronaldo's millions, could happen across this company and begin asking too many questions. Ronaldo was the brand that had to remain spotless, the name on which Mendes had staked his success.
75 Million for Ronaldo

Ronaldo signed with Real Madrid in 2009 after his new club had paid a record transfer fee of 94 million euros. On a hot day in July 2009, 80,000 fans filled Bernabéu Stadium not to watch a football match, but to bow down to their new football god. Ronaldo, who was 24 at the time and had already reached the peak of his talents, pulled on the white jersey of his new club. He juggled a ball, kissed a child and then the emblem on his breast. It was a grand production.

But half a year previously -- at least according to the documents, which may have been back-dated -- Ronaldo had already placed his name beneath a different contract. Without fans and without a spectacle. It was a contract that made the reigning football player of the year into the football earner of the year.

The six-page document guaranteed Ronaldo earnings, of which the majority would apparently remain hidden from the Spanish tax office. Ronaldo's contractual partner was Tollin Associates Ltd.

As was standard for Mendes clients, the football idol ceded all of his image rights to the shell company. In return, Ronaldo would be entitled to all of the earnings that Tollin would make over the course of the next six years, free of significant withholdings.

The Ireland-based companies MIM and Polaris were also involved, the same old game that had been seen with Mourinho. They were responsible for negotiating global sponsorship and marketing deals on behalf of Ronaldo and they took in the millions that resulted. Tollin was hidden in the background and marketing partners were spared from wiring money directly to a murky offshore firm.

A small portion of the money that landed in Ireland went to Ronaldo's employer Real Madrid, in accordance with their contract because they, too, were able to profit from the Cristiano Ronaldo brand, so long as his marketing earnings exceeded a certain amount. MIM and Polaris also took what was owed them in the form of commissions, sometimes up to 30 percent and thus much higher than in Mourinho's case. But everything else went to Tollin, including the multimillion lump sum that Real had paid so that it could receive a share of Ronaldo's marketing earnings.

In total, more than 70 million euros flowed to Tollin between 2009 and 2014 and for years, Spanish tax authorities probably knew nothing about Ronaldo's secret stash. It was only in his 2014 tax return -- the year in which the Tollin contract expired -- that some of the money made an appearance. But it was just 11.5 million euros.

Did Ronaldo funnel the almost 60 million remaining euros past the tax authorities?

The Greatest Gift

Ronaldo, a favorite of the football gods, would appear to be the chosen one when it comes to earthly things like taxes as well. He was able to profit from "Lex Beckham," a law passed by the Spanish government in 2004 to attract top scientists and business executives to the country with the help of a low tax rate. In practice, however, the rule quickly became an advantage for Spanish top clubs in the competition for the world's best football players.

The law bestowed foreign players like David Beckham of Britain and Cristiano Ronaldo of Portugal the status of "impatriado." The loophole was only open to those who hadn't lived in Spain during the previous 10 years and allowed those holding impatriado status to pay a lower tax rate of just under 25 percent on all of the money they earned in the country. Ronaldo's Spanish teammates, by contrast, had to pay more than 50 percent. The greatest gift, though, was the fact that Ronaldo only had to pay tax on money that he earned in Spain. Earnings from abroad, including marketing revenues, were of no concern to Spanish tax authorities.

The law was revoked in 2010 by the new socialist government, meaning Mourinho arrived in Madrid a half year too late to take advantage. Argentinian star Lionel Messi was likewise unable to benefit because he also holds Spanish citizenship. But foreign players who moved to Spain by the end of 2009 were granted a transition period that expired on Jan. 1, 2015. And it was this regulation that Ronaldo and his advisers took full advantage of.

Thanks to Lex Beckham, Ronaldo was only liable for taxes on 20 percent of the millions he earned internationally and had parked with Tollin Associates. That was the share of his marketing revenues that his lawyers estimated came from Spain -- the share on which he only had to pay the lower, 24.75 percent tax rate. The majority of his marketing earnings, that which had been earned outside of Spain, wasn't taxed at all.

The year 2015, though, marked the end of the privilege -- for Ronaldo as well. After that, like every top earner in Spain, he would be responsible for turning over roughly half of his earnings to the state -- and that included sums earned outside of Spain. But Cristiano Ronaldo apparently wasn't prepared to leave that much money to the Spanish authorities. His advisers dug deep into their bag of tax tricks- - to the murky, mucky bottom.

In late December 2014, just before the Lex Beckham transition period was set to expire, the football professional sold his image rights for the years 2015 to 2020 for almost 75 million euros -- to go with the some 75 million that had already flowed to him from Tollin, the majority of it untaxed.The buyers of the rights were two newly established shell companies on the British Virgin Islands, one called Arnel and the other Adifore, and they were once again registered at Vanterpool Plaza in Road Town on the island of Tortola.

A Hectic Transaction

The contracts were notarized on Dec. 20, 2014 in Morocco. Time was apparently of the essence: The deal had to be completed by the end of the year and Ronaldo at the time was playing in the FIFA Club World Cup in Morocco.

The contract with Arnel was for Ronaldo's image rights for Spain while Adifore holds his image rights for the rest of the world. On December 20, Ronaldo submitted an invoice to each of the two companies. From Arnel, he demanded 11.2 million euros for the Spanish rights while he billed Adifore 63.75 million for the global rights. Both payments were to be made to account No. 413416 at the small, exclusive private bank Mirabaud & Cie in Geneva. The money arrived just three days later.

According to two additional contracts, the purchase price was later to be reduced by around 15 million euros -- 3 million less for the Spanish share and 12 million lower for the global rights. Why?

It's not clear. Did Ronaldo in fact pay the 15 million back? There is no proof of his having done so in the account documents that are part of the data trove. Ronaldo's 2014 tax return likewise only lists the initially agreed-upon sum of 11.2 million in marketing revenues from Spain.

What, though, was the reason for the hectic activity in Morocco? Ronaldo apparently wanted to take advantage of the lower, 24.75 percent tax rate on his Spanish image rights for the years 2015 to 2020 before the impatriado rule expired at the end of 2014. At the same time, 2014 was also the last year that he didn't have to pay taxes on his foreign marketing earnings -- the global rights that had just earned him 63.5 million euros all at once. Taken together, the tax advantage of doing so was around 35 million euros. That's how much he would have had to pay the Spanish tax authorities had he instead earned the money in the coming years with advertising.

But there was also likely a second factor. Tax investigators at the time were closing in on Mourinho and other Mendes clients. Even as Ronaldo had been able to profit from the tax benefits, his lawyers were no longer comfortable with his company on the British Virgin Islands. They wanted Tollin to disappear at the end of 2014 following the final deal.

A Good Friend from Singapore

To sell his rights, Ronaldo needed a powerful buyer, someone who could hand over 75 million in one lump sum to pay for the marketing revenues that the player would bring in over the next six years. That person is named Peter Lim. The businessman from Singapore is worth an estimated $2.4 billion and has close ties with Mendes. And, even more important for this kind of deal, Ronaldo refers to him as "a good friend." It looks as though he was behind the two British Virgin Islands companies Adifore and Arnel.

It was almost a perfect tax-saving model for Ronaldo -- almost. In late June 2015, he filed his tax return for 2014. Julio Senn's team -- Spain's top accountants in this game against the tax authorities -- had compiled it. They listed his earnings right down to the cent. Salary from his employer: 34,672,988.31 euros, in accordance with his old contract. Assets: his house in Madrid (4.5 million euros), some money in his bank accounts for the odd purchase here and there (10,799,387 euros) and cars, including exclusive sports cars like his McLaren MP4, his Lamborghini Aventador and his Ferrari 599 (1,248,152 euros).

Not listed in his 2014 tax return, however, and apparently of no interest to the Spanish tax authorities, were his foreign assets. His 15 homes in Portugal, his accounts at St. Galler Kantonalbank in Switzerland, Banco BPI in Portugal and Banque Internationale in Luxembourg. There was likewise no word about his account with Mirabaud, a private bank in Geneva, where the 75 million from the sale of his image rights to Arnel and Adifore ended up. By the end of 2014, his deposits there amounted to more than 110 million euros.

Ronaldo had received 63.5 million euros of that sum from Adifore for his global image rights, apparently without paying a single euro in taxes. Because he didn't have to? Because the law left open this gaping loophole? Or was it more of a matter of interpretation?

Whatever the case, Ronaldo's tax accountants apparently had a difficult time deciding what they should reveal to the authorities about his marketing revenues. The day before the deadline for filing the return, the document only reflected the 11.2 million euros that Ronaldo had received from Arnel for his Spanish image rights for the years 2015 to 2020. He was apparently prepared to pay taxes on that sum.

Fearing the Worst

But what about the Spanish marketing revenues for the years 2009 to 2014 that had ended up with Tollin? The draft said nothing about that money, although Ronaldo was required to pay taxes on it.

Tollin had received 11.5 million euros from ads involving Ronaldo in Spain. This sum was ultimately included in the final draft, dated June 30, and added to the 11.2 million from the Arnel deal for a total of 22.7 million. There was no indication in any of the documents making up his tax declaration that the money came from a shell company based in the British Virgin Islands.

The Senn Ferrero team feared the worst. They wrote Osório de Castro, the tax expert who worked with Mendes, that they wanted nothing to do with Ronaldo's tax model. "We didn't participate in the structure's design, implementation or monitoring," they expressly stated. In other words, Mendes and his team were responsible. Once everything had been sent off to the tax office, a Senn employee wrote to his colleagues: "Thank God we've covered our backs a million times because I can already see that this tax return will have consequences."

And it did. An audit began at the end of 2015, initially for the years from 2011 to 2013. A tumultuous period followed for Senn Ferrero. They suddenly had to produce multiple documents as quickly as possible, including Ronaldo's contracts with Real Madrid, with his sponsors and with the Ireland-based marketing companies MIM and Polaris. The team assigned with protecting Ronaldo, led by Julio Senn, knew exactly where the weakest point in Ronaldo's tax model could be found: Tollin.

Osório de Castro, a long-time adviser to Mendes who had provided his expertise for the offshore model, realized it as well. The Senn team wanted to know from him who Tollin actually belonged to.

The response: "The information about Tollin, the most sensitive, we have to talk about it." A couple of days later, he wrote: "Say nothing about the beneficiaries of Tollin or about the administrators without speaking to me first."

Why was everybody so concerned when it came to Tollin?

Premature Relief?

Ronaldo was apparently lucky this time around as well -- or he enjoyed a significant amount of understanding from the Spanish tax authorities. There are, after all, agents there who are so close to people from Senn Ferrero that they don't just send emails to the lawyers from their official email accounts, but also from their private accounts. In the end, they declined to consider Ronaldo as the owner of Tollin, even though so much of his money flowed to the firm.

The news put Senn Ferrero in a self-congratulatory mood: "We did it." The officials don't view the companies "that do business with MIM, Tollin in this case," as being owned by the players. "Thank God."

Ultimately, the relief could prove to be premature. At first, the authorities only examined Ronaldo's tax returns up until 2013. Should they decide to take a closer look at 2014, as Ronaldo's lawyers expected they would, the role played by Tollin as well as the sale of Ronaldo's image rights to the British Virgin Islands-based companies Arnel and Adifore will become apparent.

Would the authorities once again decide that nothing was askance? Would Ronaldo again get lucky?

The decisive question is this: Was it legal for Ronaldo to claim his 2015 to 2020 image rights earnings in 2014, the last year he could enjoy the tax privileges bestowed upon him as an impatriado?

And prior to that, shouldn't all of the marketing revenues generated in Spain for Tollin from 2009 to 2014 have been assigned to him? He was, after all, the sole beneficiary of the shell company.

According to the contract, all of the money collected by Tollin belongs to him. For tax experts such as the German-Spanish lawyer Rafael Villena from Hamburg, who has spent years examining such structures, the situation is clear: "Ronaldo should have declared all of the money paid to Tollin for each year from 2009 onwards, and not only in 2014." And regarding the income from the years 2015 to 2020: "He should not have been allowed to declare it in 2014.
I can't imagine any tax authority recognizing such a thing."

The Munich-based lawyer Peter Duvinage, who has provided contractual consulting to show business stars and athletes for years, agrees. "When it comes to tax structures involving an offshore paradise like the British Virgin Islands, the alarm bells have to go off for all tax officials."

That could have been what one of Julio Senn's employees had in mind when he wrote to his boss on March 16, 2016: "The only good thing is that Tollin no longer existed in 2015."

The Reckoning

The EIC network presented the results of its reporting to stars, clubs and agencies. The extensive list of questions was primarily aimed at finding out what they knew of the activities engaged in, what they had to say about the accusations leveled against them and how they assess the documents. Ronaldo, Mourinho and their agent Mendes declined to answer. Portuguese players Carvalho, Coentrao and Pepe as well as the Colombian Real Madrid star Rodríguez also didn't respond. Neither did we receive a reply from billionaire Peter Lim nor from the Ireland-based companies MIM and Polaris.

We did, however, receive a statement from Osório de Castro, Mendes' tax expert. "I have nothing to do with the construction of a company structure for image rights for the players named," he wrote. He likewise "categorically" denied all accusations and said he refuses to say anything about professional issues or clients as a matter of principle. Osório de Castro inveighed against the "witch hunt" and said the leak stemmed from the theft of data from the tax accounting firm Senn Ferrero. The documents taken were then "distorted and manipulated," he wrote.

People from Senn Ferrero also claimed that some of the documents were faked, though the Spanish tax attorneys didn't want to be directly quoted. But around two weeks ago, a PR representative claiming to be from Senn Ferrero visited the offices of EIC partner El Mundo in Madrid. He handed over a two-page memorandum printed on paper with no letterhead. It said that in the case of Mourinho, the tax authorities had always known of the company Koper on the British Virgin Islands.

In Ronaldo's case, the letter noted, tax investigators are taking a closer look at the tax constructions, as they are doing for so many athletes. The tax law firm, the letter stated, does not believe that the tax officials will find anything objectionable. Here, too, it was claimed that the documents in the possession of journalists are fakes.

EIC did all it could to determine the authenticity of the documents and neither SPIEGEL nor any of its partners came across any indication that the papers were either fakes or had been partially manipulated. In prior SPIEGEL articles stemming from the Football Leaks data trove, not a single document was revealed to have been falsified. Senn Ferrero and Osório de Castro likewise declined to identify which documents they thought had been manipulated.

On Friday, Gestifute, the company belonging to Jorge Mendes, published a statement on its website pertaining to the Football Leaks documents. "Both Cristiano Ronaldo and José Mourinho are fully compliant with their tax obligations with the Spanish and British tax authorities," the English version of the statement reads. It continues: "Neither Cristiano Ronaldo nor José Mourinho have ever been involved in legal proceedings regarding the commission of a tax offense." The statement also says that in cases where there have been "disagreements" between Gestifute clients and "the respective tax authorities," they have been resolved without the need for legal proceedings. Gestifute did not comment on questions relating to costs linked to Koper in the Mourinho case.

Later, a British public relations agency that represents agent Mendes and stars Mourinho and Ronaldo issued a statement saying that Mendes himself never had anything to do with players' tax models. It said they had been created at the request of the teams and with the help of tax advisers. In addition, in Mourinho's case, it stated, the authorities had not been deceived during tax audits in Spain and England.

Real Madrid left most of the questions unanswered, justifying their reticence by noting that the data breach had been illegal. Furthermore, the club said, the data contained personal information about which only the individuals involved had a right to comment and not the club.

Real Madrid insisted that it consistently obeyed the applicable laws, noting that in cases where Real paid for image rights, the club always withheld the taxes due and transferred them to the state in accordance with Spanish law. Here, the club is likely referring to the 10 percent that was in fact paid to the tax office when Real paid the Irish company MIM for advertising with Ronaldo or Mourinho. That is why, the statement from Real continues, no "irregularities" have been discovered in instances when the club's taxes have been audited.

Former Real Madrid player Mesut Özil has appealed against the tax penalty levied against him and his lawyer declined to comment on the case. Spanish tax authorities also didn't make a statement.

In England, the London-based club Chelsea insisted that it has always obeyed prevailing law when it comes to payments for image rights, including in the case of Mourinho.

English tax authorities, however, declined to give the all-clear. They indicated that they wouldn't comment on individual cases, but added that the tax authority "carefully scrutinizes the arrangements between football clubs and their employees in respect of any image right payments to make sure the right tax is paid." They added: "We take seriously allegations that customers or their agents may have acted dishonestly in the course of an inquiry and can reopen closed cases if we suspect this has happened."

It sounds almost like a threat, and one that Mourinho would be well advised to take seriously this time. Because in the end, it won't be journalists passing final judgment on his and the others' Caribbean adventures. It will be the judiciary.


By Rafael Buschmann, Jürgen Dahlkamp, Stephan Heffner, Christoph Henrichs, Andreas Meyhoff, Nicola Naber, Jörg Schmitt, Alfred Weinzierl and Michael Wulzinger

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