Sovereign didn’t respond to requests for comment.

Following Sovereign Group’s advice, Messi sold the rights to market his image in 2005 for $50,000 over 10 years to Sport Consultants Ltd., a company in Belize owned by Celia Cuccittini, his mother, according to the prosecutor’s complaint.

After turning 18, Messi himself ratified the sale of his image rights to Sport Consultants in 2006.

Adidas Deal

Four days later, a separate U.K. company owned by Messi’s father and Schinocca, and acting on behalf of Sport Consultants, signed Messi to a sponsorship deal with Adidas worth 9 million euros over six years. At Adidas’s request, Messi and his mother confirmed in a notarized document that its payments were going to Sport Consultants in Belize, Schinocca said.

The mismatch between Messi’s sale of the rights for $5,000 a year and their resale for 1.5 million euros a year to Adidas is a red flag for tax authorities, said Garcia, the Spanish attorney for soccer players.

“When the players sell their rights to the image-rights company, it has to be on a market value,” he said.

After a falling out with Schinocca, the Messis transferred the image rights in 2007 from Sport Consultants to Jenbril SA, a company in Uruguay owned by Messi.

Belize, Uruguay

Neither Sport Consultants nor Jenbril contracted directly with sponsors. Instead, they licensed Messi’s image rights to companies in the U.K. and Switzerland, which in turn sold the rights to corporate sponsors and to Messi’s Barcelona team. Payments to Messi under these deals were funneled back to the Belize and Uruguay companies.

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