Xavi Hernandez remains dissatisfied with the partial ruling issued to the tax authorities after a decision announced recently. The coach has chosen to pursue the matter in the Netherlands, according to El Periódico de España, part of the Prensa Ibérica group, citing sources close to the Catalan. The aim is to defend how he remunerated his image rights during his stint with Barcelona and to seek a full annulment of the 2.5 million euros demanded by the treasury for those years.
The Administrative Chamber’s Fourth Division delivered a mixed, though favorable, verdict in early October. This article has obtained the ruling for the first time. It explains that the coach channelled his image rights through a company registered in his name to reduce the tax base and, consequently, the amount of tax payable on that income. The decision describes this arrangement as a “simulation” designed to create tax advantages.
As with other high-profile cases, such as that involving Dani Alves, who faced prison consequences before resolving a multi‑million euro dispute, the justice system acknowledges certain missteps in how image rights earnings were reviewed. This has led to judgments that sometimes overturn prior conclusions and recognize that earlier assessments were flawed in determining which payments qualified as taxable income.
The treasury had demanded 2.5 million euros in the Xavi Hernandez case. Only parts of 2013 and 2014 were cancelled. Sources close to the coach expressed guarded optimism about the appeal, telling this newspaper, “We prefer not to discuss the amounts to avoid complicating the ongoing appeal.”
Even with the partial victory, Xavi pushed forward with additional arguments that the National Court did not accept. For instance, the court disagreed with him on whether payments made by Barcelona to his representative agency should be treated as a separate stream of income or halted for tax purposes. The treasury and the National Court held that the arrangement served the club and the player as a tax advantage rather than a genuine business arrangement. The ruling elaborates that the structure allowed both sides to minimize declared business income while permitting the club to deduct input VAT that otherwise would have been lost.
According to the decision, the mechanism required intent and knowledge, and the parties pursued specific goals to reduce the tax base. The case concerns two years that correspond to Xavi’s final period with Barcelona, including his announcement in May 2015 that he would leave the club he loved to continue his career elsewhere, a transition culminating in his retirement from playing in 2019 and eventual return to Camp Nou as a coach.
The sentence, dated at the start of October, notes how Galileu 136, a company in which Xavi holds substantial control, was used to manage image rights and the revenue derived from them across the national territory. Inspectors from the tax authorities found that this setup did, in fact, reduce the declared tax base and led to agreements totaling 2.5 million euros intended to minimize tax liability. In response, Xavi appealed to the Central Administrative Economic Court within the ordinary justice system, which did not share the TEAC stance in 2019 and, in its subsequent rulings, granted partial affirmation of his arguments.
The discussion about the origin and valuation of the money in question centers on the connection between Galileu, Barcelona, and Xavi. The National Court previously viewed these payments as part of a business triangle and questioned whether they exceeded legally permissible limits. Xavi has faced similar challenges before, including cases with former teammates Andrés Iniesta and Carles Puyol, where the courts accepted that the tax authorities had misclassified payments—a claim that has, on occasion, earned the player compensation in other disputes dating back to 2009 and 2012. These historical precedents underscore the ongoing debate over how image rights transactions should be interpreted for tax purposes and how they should be treated under the law.
The broader legal question remains whether the arrangements surrounding the image rights and the related payments were genuinely business transactions or deliberate strategies to gain tax advantages. The National Court’s stance in earlier judgments reflected a willingness to scrutinize such structures carefully, while recognizing that some of the previous conclusions could be revised in light of new arguments and demonstrated intent. The current appeal is part of a broader pattern in which high-profile athletes and clubs have challenged tax authorities over the treatment of image rights and related compensation, signaling a continuing evolution in how these income streams are analyzed for tax purposes. The case continues to unfold as authorities and the courts weigh the legality and fairness of the arrangements that benefited both the player and the club over several seasons, with ongoing implications for how similar earnings will be assessed in the future. Attribution: coverage provided by El Periódico de España, part of the Prensa Ibérica group, based on information from sources close to the case and court records.