Overview
- The Audiencia Nacional issued a ruling dated 22 April 2026 that annulled the 2005 IRPF liquidation and its related sanction against Samuel Eto'o on procedural grounds.
- The court found the tax inspection exceeded the 12‑month maximum effective duration in force at the time, which caused the Administration's right to collect the 2005 tax to prescribe.
- As a result Eto'o will not have to pay roughly €409,000 in regularization (quota and interest) nor the proposed 125% fine, and the ruling orders the tax authority to pay the case costs.
- The judgment overturned earlier adverse administrative rulings by the TEAC and the regional economic‑administrative tribunal but did not decide whether Eto'o used interposed companies to channel image‑rights income.
- The decision can still be taken to the Tribunal Supremo by means of a casación appeal, so the ruling’s final legal effect and its influence on future tax inspections remain unresolved.