You're on the right lines I believe. Fordham was about bringing revenue in via an up-front lump sum, rather than tax avoidance, and my view is that was done to try to help us avoid sanction under FFP.
Although we knew we were going to fail, the Annex XI provision about pre-2010 wages gave us a get-out if we could show that these wages were the sole reason for our losses. Knowing what those allowable wages were, we knew what the maximum allowable loss was, and the Fordham payment was (in my view) a device to help us achieve that.
Of course, as we now know, UEFA made a change to the method of calculation about those wages and how they could be applied, which made us fall just outside the maximum allowable loss. I suspect that we probably wouldn't have bothered with the Fordham arrangement had we known the way it would play out but it was too late once we did know.
Image rights are certainly a device to minimise tax payments, by paying a player's company for the use of their image. The tax burden then falls on the player's company, rather than the club. If the club pays a player £100k a week, with no image rights, the club will pay tax & NI on that full £100k. By paying £90k in salary and £10k in images rights, the club reduces its tax & NI liability by £10k. HMRC's rule of thumb is that, under normal circumstances, 10% of a player's remuneration is acceptable. I suspect the disputes with the likes of united and Newcastle are over the amounts paid, and therefore their tax liability.
