Manchester City's defence in their appeal against the independent commission's guilty verdict in more than 100 charges of financial rule breaches appears to be contradicted by previous statements made by their main sponsor, Etihad Airways, to the US government.
A key element of City's appeal, which was confirmed by the club on Friday, is understood to be based on their claim that commercial contracts, which the commission concluded were part-funded by their owner, were in fact paid for by the Abu Dhabi government.
In a 2015 submission to the United States' department of commerce, transportation and state as part of investigation into state-owned airlines, Etihad described suggestions that the government paid for its sponsorship of the club as "false".
Etihad, the state-owned national airline of the United Arab Emirates, has been City's principal shirt sponsor since 2009 and was the main source of the initial transformation of their revenue that followed their purchase by Sheikh Mansour's Abu Dhabi United Group (Adug) the previous year.
In 2011 City announced a 10-year naming rights deal worth £400m for the Etihad Stadium, which was extended on improved terms in 2021.
The Etihad submission to the US department of commerce said: "The assertion that the Abu Dhabi government paid for Etihad's sponsorship of English Premier League football club Manchester City is false. In 2011, Etihad and Manchester City entered into a 10-year sponsorship agreement, which included naming rights for Manchester City's stadium. Etihad funded this sponsorship from its own liquidity.
"We are government-owned and have been since our founding. We are and have always been clear that we do not receive any subsidies from the Abu Dhabi government, and that we are financed through a combination of equity, shareholder and commercial loans.
"Our shareholder [the Abu Dhabi government]'s equity and loans are not subsidies under any applicable definition; they are the means by which the Abu Dhabi government has sensibly invested in a successful business model."
City's argument is also a departure from the position the club took in their successful appeal against Uefa's charges of breaching financial fair play rules at the court of arbitration for sport in 2020, when they maintained that all their sponsorship income was provided by their commercial partners.
The commission dismissed City's argument as "untrue" in its core decision published on Tuesday. Paragraph 77 of the judgment states: "We concluded that it was an 'explanation' that the club had concocted well after the event in an attempt to obscure and conceal the realities of the Disguised Funding Scheme." City submitted their appeal on Thursday evening and insist they have "a body of irrefutable evidence" that will prove the commission's findings to be untrue.
The Football Association has confirmed it has powers to take disciplinary action against City and key individuals at the club. The FA said the independent commission's decision on City had "significant implications for the integrity of the game" and that it "will take action where appropriate".
The FA will wait until the appeal process has concluded – which based on the Premier League's rule book should be by the end of January – before deciding whether to take action but said it was monitoring the case closely.
The FA has powers to take action against individuals proved to have broken rules and/or acted dishonestly, which the commission concluded had been the case. The names of those involved were redacted in the 40-page core judgment published this week but the FA could ask the Premier League for an unredacted version.
"The Independent Commission's decision has significant implications for the integrity of the game," the FA statement read. "We are carefully considering the decision and its implications and will take action where appropriate.
"As proceedings between the Premier League and Manchester City Football Club remain ongoing, we do not intend to comment further at this stage. We will, however, continue to monitor developments closely."
The FA's standard practice is to wait for disciplinary proceedings conducted by leagues, such as the Premier League or EFL, to run their course before taking action.
In July the FA fined Chelsea £10m and imposed a suspended two-window transfer ban after the club admitted 74 breaches of its agent regulations, four months after the Premier League fined them £10.75m for the same offences, which related to unlawful payments to players and agents. The FA has additional powers to take action against individuals, although did not do so in the Chelsea case because those involved are no longer working in football.
The FA charged Southampton's manager, Tonda Eckert, with misconduct for his role in the so-called Spygate saga involving Middlesbrough in May, with a disciplinary hearing taking place last month that could result in the German being given a lengthy ban from football.