Spain's public prosecutor has recommended the punishment of a jail sentence and fines totalling more than two million euros for allegedly defrauding the state of 4.2m euros (£3.1m) between 2007 and 2009.
The prosecutor reiterated that the Barcelona star should not have to face charges because it was his father who was in charge of his finances in that time, which has been proven by documents published on Tuesday, The Sky Sports reported.
However, the court overseeing the case already rejected Lionel's appeal last year, ruling that he may be liable for approving the creation of a web of shell companies that were allegedly used to evade tax due from his image rights.
According to the prosecutor's office, the UK played host to one of these shell companies used to hide revenue as well as Uruguay, Belize and Switzerland.
Lionel and his father paid 5m euros (£3.7m) to Spain's tax authorities as a "corrective payment" in 2013, having been formally charged.
The Argentina forward, who has been resident in Barcelona since 2000 and gained Spanish citizenship in 2005, is 10th on Forbes Magazine's list of the world's highest-earning athletes over the past decade, with an estimated income of £230m.