Former Barcelona and Cameroon striker Samuel Eto’o has won a landmark legal victory against Spain’s tax authorities, with the Audiencia Nacional (National Court) ruling in his favour in a dispute dating back more than two decades.
The court annulled previous decisions requiring the 45-year-old football legend to pay approximately €900,000 relating to his 2005 image rights income, ruling that the tax inspection exceeded the legal time limits permitted at the time.
The ruling brings to a close the final unresolved chapter of Eto’o’s long-running tax saga in Spain.
Background: A decade of legal battles
The case stems from Spain’s historic crackdown on high-profile footballers, artists, and celebrities suspected of using shell companies to reduce their tax liabilities through image rights income.
Spanish authorities alleged that Eto’o received substantial income from the transfer of his image rights to sponsors including Puma, FC Barcelona, and video game distributor Electronic Arts during his playing career. They argued these funds were improperly channelled through two companies — Spanish entity Bulte 2002 Empresarial and Hungary-based Tradesport and Marketing — rather than being declared directly as personal income tax (IRPF).
The tax authorities sought to recover more than €409,000 in unpaid tax and interest, to which they added a 125% penalty for what they classified as a very serious tax infringement, bringing the total claim to approximately €900,000.
Previous convictions for later tax years
The 2005 case was the only remaining unresolved matter from Eto’o’s tax affairs in Spain. In 2022, the former Inter Milan and Anzhi Makhachkala forward reached a settlement with prosecutors relating to tax years 2006 through 2009.
Eto’o accepted responsibility for €3.8 million in tax fraud spanning four years, received a 22-month prison sentence, and paid €1.8 million in fines. The prison term was suspended — a common outcome for first-time offenders in Spain.
His former representative, José María Mesalles, received a one-year sentence as an accomplice.
The winning argument: Time limits expired
The Audiencia Nacional did not rule on whether Eto’o actually owed the disputed taxes or whether his corporate structure constituted legitimate tax planning. Instead, the court focused on a procedural technicality that proved decisive.
In a ruling dated April 22, 2026, made public this week, the court found that Spain’s tax inspection for the 2005 financial year had extended beyond the legal time limits in force at the time.
The inspection lasted 877 days — over two years. While tax authorities claimed they had legitimately discounted 514 days attributable to delays caused by the taxpayer or justified interruptions, leaving just 363 effective inspection days, the court rejected this calculation.
The judges found that the tax agency had failed to adequately justify the “real impact” of these alleged delays. One critical example involved a 223-day delay attributed to Eto’o’s representative failing to provide a 2004 contract with FC Barcelona. The court noted that inspectors could have obtained the document directly from the club months earlier and ruled the delay should have been limited to just 24 days.
“Once the player’s representative stated he could not obtain the document, the Inspection could have gone directly to the club to request it,” the court stated.
With these unjustified delays removed, the effective inspection period exceeded the legal twelve-month limit, meaning the tax authority’s right to assess the 2005 liability had expired.
Victory follows Shakira precedent
Eto’o’s victory comes just weeks after the same court ruled in favour of Colombian singer Shakira in a separate tax dispute. In mid-May, the Audiencia Nacional determined that Spain’s tax agency had failed to prove Shakira was a fiscal resident in 2011, annulling a €60 million claim.
However, the legal path may not be finished. Spain’s tax authorities have already indicated they will appeal Shakira’s case to the Supreme Court, and Eto’o’s ruling remains similarly susceptible to appeal.
Career legacy
Samuel Eto’o Fils, now president of the Cameroon Football Federation (FECAFOOT), is widely regarded as one of Africa’s greatest footballers. During five seasons at Barcelona from 2004 to 2009, he scored 152 goals in 234 matches and won two Champions League titles (2006, 2009) and three La Liga championships.
He was the league’s top scorer in the 2004-05 and 2005-06 seasons — the very years now central to this tax dispute.
With an estimated net worth of $95 million, Eto’o has built a substantial post-playing career that includes football administration and philanthropic work through his foundation.
The court imposed legal costs of approximately €409,300 on Spain’s General State Administration — the amount Eto’o was originally told he owed in tax and interest.
