Jose Mourinho is at the centre of a tax avoidance storm amid allegations that advisers stored £10m of his income over a decade into a shell company based in the British Virgin Islands.
More than 17 million football-related tax documents leaked to European news outlets, including the Sunday Times, claims money paid by Chelsea, Italian club Inter Milan and Spanish giant Real Madrid for Mourinho's image rights up to 2014 was transferred to a Swiss bank account with zero or only minimal tax deducted.
Charges to use his image on merchandise formed a big part of Mourinho's income: his basic pay fell from €17.63m (£15.2m) to €14.9m (£12.8m) when he moved from Inter Milan to Real Madrid, but the La Liga giants agreed to pay him €2.3m (£2m) a year for his image.
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"Big corporations including Adidas, Procter & Gamble and Saudi Telecom Company poured in hundreds of thousands more," says the Sunday Times.
It is claimed the bank account was controlled by Koper Services, a British Virgin Islands-registered company to which Mourinho signed over his image rights. In turn, the firm then licensed them to Multi-Sports & Image Management of Ireland, which collected the money.
Koper was ultimately controlled by a "professional" corporate director that acted on behalf of a trust called Kaitaia, the ultimate beneficiaries of which, the leak says, were Mourinho's wife and children.
HMRC investigated the case and Mourinho admitted he had not met of his tax obligations. However, by claiming huge expenses for Koper, he was able to reduce the eventual back-tax bill to £288,300 – "about £300,000 less than if he had not claimed any costs", says the FT.
The ruling was cited as a defence against an investigation by Spain's tax authority which resulted in a bill of £2.8m and a penalty of £950,000.
The remainder of the money has remained in Mourinho's name and no criminal charges were ever brought. However, experts in the UK and Spain are now calling for the cases to be re-opened.
The Sunday Times says it is not clear how much Mourinho knew about the affair and how much is down to his advisers, including his "close friend and agent Jorge Mendes".
Lawyers acting for both men said: "The Spanish tax authorities confirmed in a certificate issued a few days ago that Mr Jose Mourinho is fully compliant and up-to-date with his tax obligations.
"His tax affairs have never been the subject of a criminal investigation or prosecution.
"Mr Mendes and [Mendes's personal lawyer, Carlos Osorio de Castro] are not tax advisers and never recommended any image rights structures to the players. All structures were created at the request of the clubs on the advice of tax professionals from the relevant jurisdictions.
"There can be no suggestion whatsoever that Mr Mourinho, Mr Mendes or Mr Osorio de Castro have committed any criminal offence."
