In November, the tax tribunal, in a split decision, sided with Rangers’ position that the trust payments weren’t taxable. An HMRC appeal is pending.

Since prosecutors filed a complaint against Messi in June, his case has rocked the world of international soccer, where he is revered as a once-in-a-generation talent. The only four-time winner of the Ballon d’Or, awarded to the world’s best player, Messi was named this year to World Soccer Magazine’s all-time football team, joining legends such as Pele and Diego Maradona.

Soccer Prodigy

Messi, his girlfriend and his infant son live in a duplex in Pedralbes, one of Barcelona’s most exclusive neighborhoods, where the younger daughter and son-in-law of Spain’s King Juan Carlos recently put their mansion up for sale for 9.8 million euros. Messi’s fleet of cars includes a 150,000-euro Maserati Gran Turismo MC Stradale. The 10th-highest paid athlete in the world, Messi earns $20 million in salary and prize money and $21 million in endorsements, Forbes.com estimated this year.

Messi has been a soccer prodigy since he started playing for Newell’s Old Boys in Rosario, Argentina, as an 8-year-old. Diagnosed with a growth hormone deficiency, Messi moved to Spain with his father at 13 after Barcelona offered to pay for his hormone treatment. At 5-foot-7, Messi is shorter than most soccer players and is nicknamed La Pulga, or The Flea.

Tax Shelter

By 2004, Barcelona was paying the 16-year-old more than 15,000 euros a month. His family contracted with Schinocca, 51, to sell his image rights, according to court documents.

A former professional player in Argentina for Boca Juniors, whose career was cut short by an eye injury, Schinocca was a partner in a sports marketing firm in Buenos Aires. It also represented Diego Forlan, a Uruguayan star who played for Manchester United.

Messi’s parents -- acting for him because he was still a minor -- asked Schinocca to set up a tax structure to shelter his future earnings, according to Spanish prosecutors.

Schinocca and Jorge Messi contacted Sovereign Group, a Gibraltar-based management company, Schinocca said. The Sovereign Group specializes in helping the wealthy avoid taxes by setting up corporations and trusts, including offshore corporations, according to its website. Founded in 1987, it has offices in 24 countries and jurisdictions that manage more than 7,000 client “structures.”

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