You might need to refresh your understanding of the word Pay-to-Win.
At any point where you can pay for an advantage whether it be Pay-to-Skip or pay to get an OP ship or whatever. As soon as it has any gameplay effect on other players it is Pay-to-Win whether you like it or not. The only thing that is not Pay-to-Win is cosmetics. Since they only apply a skin to an already existing ship. It is even Pay-to-Win if the ship you buy is worse than the starter ship, though for the love of me I would not think of anyone except collectors that would buy that.