Yeah, that was my reading of it too. They seem to be most concerned about where the finance is from rather than how it's structured or used.
This does kind of make sense from their perspective as they only seem to be looking at football's finances from abroad and any tax avoidance issues, so if your finance is coming from or through places like the Cayman Islands, Bahamas, etc then that is likely to be because some level of tax avoidance is involved.
We're at the top simply because we have a global setup (CFG) which involves huge amounts of money and they say Abu Dhabi has a high secrecy score on the "Financial Secrecy Index".
They go on to say that there's nothing secret about our finances and that City are "on a far more sustainable financial footing than others." so it's odd that they've even included us in something like this.
It looks like they've added us simply due to geography rather than any measure of secrecy round ownership, as in the case of Bournemouth and Bolton, or general levels of tax avoidance, like Spurs and United.
Foreign investment is hugely important to the UK but we should make sure that it's as transparent as possible to try to put a stop to as much tax fraud as possible. This will never happen though as one of the benefits of using tax havens and top accountants to exploit loopholes is that you tend to be extremely rich which gives you a lot of power.