I will write more as the matter unfolds. In simple terms: these documents would build the picture to strong evidence.
- Sponsorship agreement between Etihad and Manchester City;
- Audited accounts for the relevant year;
- BDO audit committee observations and report document covering key areas of review and materiality;
- Management representation letters to BDO;
- Relevant invoices from Manchester City to Etihad;
- Bank statements showing the deposit from Etihad to Manchester City in the sums referred to in the sponsorship agreement;
- Evidence of third party offers in excess of the Etihad sponsorship to verify the commercial rates being charged to Etihad (ie even if they were related - fair value was higher than or around what Etihad are paying);
- Copy of PwC Report to UEFA showing the amounts disputed even before the settlement;
- List of documents provided to PwC before the release from the settlement agreement in April 2017.
City are wrong to use the term "irrefutable" in circumstances where the Adjudicatory Chamber has, indeed, refuted the evidence.