Clubs are required to adhere to the convention ( if that’s the right word) agreed or allowable under HMRC regulations.Image rights have been the subject of a number of tax tribunals. In terms of HMRC they really didn’t get a clear direction until 2019
As long ago as 2109 over 44 professional clubs and 177 players were under investigation following issues around payment of image rights.It used the be the case that there was an acceptable % paid by way of image rights but the approach now is that the image rights payments are valued on a player by player basis.Such valuations are independent.
Under both FA rules and indeed copied into the PL rule book (I can’t find such restrictions in either FIFA or UEFA rule sums payable have to be paid by the club or from a subsidiary company within the group.I am not sure that’s an historical rule but suspect the wording in older FA versions would have said something along the lines all payments have to be made by the club.
As the image rights have to be included in the players standard contract they can not be paid by a third party
It is allowable to pay the image rights into a UK registered company but payments to an offshore company are considered to be remuneration and subject to both PAYE and Class 1 NIC.
My understanding is that when Bohley and his associates purchased Chelsea issues with taxation apparently part of which revoked around image rights was an issue and Chelsea seemingly made a voluntary disclosure.