In a statement, the prosecutor's office alleged that the Real Madrid star and four-time Ballon d'Or winner had knowingly used a "business structure" created in 2010 to hide his income in Spain from his image rights, and described his failure to pay the correct tax as "conscious and willing."
The lawsuit is based on a report sent to the prosecutor's office from Spain's tax agency AEAT, it said.
Ronaldo took advantage of what is known in Spain as 'the Beckham law' - which allows foreign sportspersons to pay 24.75% income tax, rather than the 48% applied to Spanish nationals. Athletes must still, however, pay taxes on other income earned in Spain.
In Cristiano's case, the former Manchester United winger is accused of having diverted some €150m of advertising revenue through the British Virgin Islands.
Ronaldo becomes the latest high-profile footballer to become involved in a Spanish tax case.
Barcelona superstar, and Ronaldo's long-term rival, Lionel Messi was sentenced to 22 months in prison for a €4.1m fraud, but avoided jail by paying a fine and agreeing to probation.
Ronaldo's representatives did not respond immediately to a request for comment.
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