Spain's tax agency asked the Supreme Court to review the ruling that annulled a 55 million euro debt against Shakira.
The request follows the April ruling that cleared the singer for the 2011 tax year. A judge found Shakira spent only 163 days in Spain that year, below the 183-day threshold for tax residency.
Shakira accepted six tax fraud charges for the years 2012 through 2014. After the initial win she dedicated the outcome to citizens who face a presumption of guilt from the system.
The agency seeks to revive discussion on audit methods such as credit card records and photographs. The case keeps public focus on tax inspection practices in Spain.