Yes however the part that people are missing he is being paid in the UAE for work in the UAE, it was mentioned that a lot of city recruits would be asked to do 3 or 4 days ambassadors work in the contract with a separate contract for the players manager self employed company, so if they earned money in the US for 3 or 4 days work they would have to pay US tax on the payment which would normally be paid into a us bank account, he would only be liable for UK tax if the money was paid from a US company into a UK bank account.
Since there is no income tax in the Middle East and some players/managers like Manchini would 100% been shown how to set up a UAE bank account to facilitate these payments, providing he has proof that he attended the country to work, there is very little HMRC or the PL can do even though it’s clearly wrong.
It’s not a far fetched stretch to think that City during their early years made alternative and additional payments to circumnavigate FFP rules at the time, if and it’s a big if, because as yet no one has come forward with any proof, City said to Mancini that we can only pay you £6m yearly salary for 4 years in the UK to be complicit in PL rules and UK tax law but to make your salary up to the £10m that you want we will create a secondary ambassadorial contract and pay you in the UAE tax free a further equivalent to £4m and we’ll make sure that all the photo shoots and pre season tours are conveniently located in Abu Dhabi prior to the season start, I very much doubt the current Uk government, especially with how much they rely on the Middle East would ask HMRC to go after non UK residents for incomes that may or may not have been earned In foreign countries?