Messi image-rights structure
Phase 8 Final §8.2 — Arm 2, the Messi image-rights flow (buildable; BCN-001/004/005)
A fully adjudicated and closed personal tax matter. The Audiencia Provincial de Barcelona found that companies wanting to exploit Messi's image commercially contracted through companies in the United Kingdom and Switzerland, while the rights themselves sat with companies in Belize and Uruguay. Three IRPF offences for 2007–2009 were convicted in 2016 and confirmed by the Tribunal Supremo in 2017.
On a narrow screen this flow is presented as vertical step cards rather than a diagram, so nothing here requires pinching or panning. The step cards below are complete.
Step by step
The complete record of this flow, in reading order. Every element states whether it is documentary or reported, and links the source records it rests on.
Payer layer
Companies licensing the commercial use of Messi's image.
Commercial payers — image-rights licensees
DocumentaryPayer · Licensee companies (not itemised in the retrieved record)
The judgment establishes that this layer existed and how it contracted. It does not itemise the individual licensee companies, and this record does not name them.
Sources (2)Onward connections (5)
toSport Enterprises Ltd.Documentary
Services contracted through a UK company
Contract
Sources (2)toSidefloor Ltd.Documentary
Services contracted through a UK company
Contract
Sources (2)toLazario GmbHDocumentary
Services contracted through a Swiss company
Contract
Sources (2)toVitop Consulting AGDocumentary
Services contracted through a Swiss company
Contract
Sources (2)toTubal Soccer Management GmbHDocumentary
Services contracted through a Swiss company, from 2007
Contract · From 2007
Sources (2)
Contracting layer — United Kingdom and Switzerland
The companies through which those services were contracted.
Sport Enterprises Ltd.
DocumentaryContracting company · Agent company · United Kingdom
Note the near-identical name to Sport Consultants Ltd. (Belize). They are different companies in different layers and must not be conflated.
Sources (2)Sidefloor Ltd.
DocumentaryContracting company · Contracting company · United Kingdom
Controlled through Bedford Nomines (UK) Ltd and West England Trust Limited per the prosecution's account. Neither nominee company is separately represented in this record.
Sources (2)Lazario GmbH
DocumentaryContracting company · Contracting company · Switzerland
Recorded as the first structure used.
Sources (2)Vitop Consulting AG
DocumentaryContracting company · Contracting company · Switzerland
Identified in the record as a capital provider.
Sources (2)Tubal Soccer Management GmbH
DocumentaryContracting company · Contracting company · Switzerland
Sources (2)
Income routed to the cessionary layerDocumentary
The judgment establishes the two-layer structure — UK and Swiss contracting companies above, Belize and Uruguay cessionaries below. It does not establish which individual contracting company paid which individual beneficiary company, so this is drawn between the layers and not between named companies. Inventing those pairings would be a construction the record does not support.
Sources (3)Beneficial cessionaries — Belize and Uruguay
The companies holding the rights and receiving the income.
Sport Consultants Ltd.
DocumentaryBeneficiary · Cessionary company · Belize
Administered by Celia Cuccittini per the Fiscalía querella. The rights were ceded for USD 50,000 when Messi was 17 — a price the Audiencia Provincial called illogical.
- Consideration
- USD 50,000
- Ceded by
- Lionel Messi, aged 17
Sources (3)Goodshire S.A.
DocumentaryBeneficiary · Beneficiary company · Uruguay
Ultimate beneficiary: Jorge Horacio Messi.
Sources (2)Jenbril S.A.
DocumentaryBeneficiary · Beneficiary company · Uruguay
Lionel Messi sole shareholder from 2007.
Sources (2)
Adjudication
Adjudicated and closed
Three offences against the Public Treasury (IRPF 2007, 2008 and 2009), €4.1 million defrauded on image-rights income. Convicted by the Audiencia Provincial de Barcelona, Sección 8ª, on 5 July 2016; confirmed by the Tribunal Supremo in STS 374/2017 of 24 May 2017, which dismissed Messi's appeal in full and reduced Jorge Messi's sentence from 21 to 15 months as cooperador necesario. Custodial terms were substituted for fines at €400/day in about July 2017. Charged is not convicted, convicted is not served, and served is not paid: he was charged in 2013, convicted in 2016, confirmed in 2017, never served custody, and paid a fine in substitution. There was no plea bargain to acquittal — the Fiscalía itself sought his acquittal, and the conviction rested on the Abogacía del Estado. The BORME and Registro Mercantil registration numbers for these companies were not retrieved.
The entities on this page also appear in the curated relationship scenes, and every source cited here has its own source record.