Shakira has changed lawyers in the tax fraud case that will take her to the defendant's dock, but her line of argument has hardly moved: she insists that she did not live in Spain stably until 2015, and therefore, she should not have paid here your taxes.
Four months after learning that the Prosecutor's Office is asking her for more than eight years in prison, the Colombian singer has presented her defense brief to the judge.
Shakira affirms that her professional commitments and her "philanthropic work" led her to "travel around a multitude of countries" around the world until, at the end of 2014, she decided to settle in Barcelona with former Barça soccer player and former sentimental partner Gerard Piqué .
Since the possibility of a pact with the Prosecutor's Office vanished, Shakira has raised the tone of her criticism of the Spanish authorities.
In her letter, which EL PAÍS has accessed, she accuses the Tax Agency of an "excessive collection effort" and of wanting to "instrument it for exemplary purposes."
The artist points out that, since 2011, she has paid 104 million euros in taxes worldwide, 90 million of them in Spain.
And she remembers that, from the first day - even before the lawsuit - she voluntarily returned the money that the Treasury claimed from her.
The Prosecutor's Office maintains that, between 2012 and 2014, Shakira spent 183 days or more in Spain, the requirement established by law for a citizen to be considered a tax resident.
In that period, she allegedly defrauded 14.5 million in personal income and wealth taxes.
The public ministry, which during the negotiations opened up to the possibility of a penalty that did not imply the singer's imprisonment, requests eight years and two months in prison and the payment of an additional fine of 23.7 million euros.
That is the thesis that is now trying to discredit the defense of the singer, led by the Barcelona criminal lawyer Pau Molins, in the third change of lawyers since the case began.
The accusation "is based on the erroneous assumption that Mrs. [Isabel] Mebarak [Ripoll] has resided in our country since 2011."
The lawyers insist that Shakira has been a tax resident in the Bahamas since 2004 and they hold a certificate issued by the authorities of that country.
But the prosecution had previously dismantled the argument: this certificate is issued to someone who buys a home of a certain economic value, regardless of whether or not she lives there.
"There was no firm commitment"
Regardless of the Bahamas issue, the defense claims that Shakira was a very busy woman who was "forced" to travel all over the world.
In the summer of 2010, she met Piqué at the World Cup in South Africa.
And the following year she began to visit Spain "sporadically" to "meet the athlete on the few days off that her intense professional schedule allowed."
The defense points out, as an argument to reinforce her thesis, that "there was no firm commitment between the two, due to their respective personal situations."
The artist and the Barça defender only saw each other in "holiday periods" or "fleeting trips", in Barcelona or in "other parts of the world".
The situation hardly changed, Shakira assures, until the end of 2014, when they decided to establish their permanent residence in Barcelona on the occasion of the birth of the couple's second child (Sasha, in January 2015) and the schooling of the first-born, Milan.
The decision coincided with Piqué's "controversial contract renewal" for five more years with Barça.
The lawyers criticize the investigation of the Treasury inspectors, who requested medical information and went to the hairdressers and beauty centers where the singer was treated to prove her residence in Spain.
In the defense's opinion, these measures “violate Shakira's right to privacy”.
They also criticize that the use of credit cards in the name of Shakira in different places is an indication.
"Unless she possesses the gift of ubiquity, her card spending in no way serves to prove the artist's physical presence."
Shakira vindicates herself in her writing.
She assures that she has always given her advisers the instruction to "pay all taxes where due."
She and she insists that she has no "need" to "create complications with the tax authorities."
To her "extended international career" is added her "extensive philanthropic work", recalls her defense, through the Pies Descalzos Foundation or Latin America in Solidarity Action (ALAS).
The singer emphasizes that in 2003 she was named a goodwill ambassador for UNICEF and that in 2011 she was appointed adviser by the then president of the United States, Barack Obama.