London, England (CNN) -- There has been a distinct mood of rebellion brewing in English football.
In Liverpool regular fan protests ratcheted up the pressure on their intransigent American owners to leave the club; in Manchester, the Old Trafford stadium has become a sea of green and gold scarves, the symbol of dissent against the Glazer family who own the famous United.
Both have found a common enemy -- a mutual dislike of foreign owners and debt -- and the message from both sets of protesters was simple: fans know what's best for the club and should have a greater say in how things are run.
According to Supporters Direct -- a group representing fan issues -- the anger in the north west of England is just the tip of the iceberg.
More than 170 teams in the United Kingdom now have direct fan involvement via supporters' trusts -- over triple the number six years ago -- ranging from total fan ownership to Arsenal's recent "Fanshare" scheme, where supporters can buy shares to get voting rights at board meetings.
The British government has even got involved, declaring in last May's joint coalition agreement that it would encourage "reform of football governance rules to support the co-operative ownership of football clubs by supporters."
It is almost universally accepted that fan involvement in club governance is a good thing -- but is conventional wisdom wrong? Is it better for fans to stay on the terrace and out of the boardroom?
Not according to David Conn, a football finance expert and author of The Beautiful game? Searching for the Soul of Football who sees Arsenal's "Fanshare" scheme as a way forward in the fight for fan involvement.
"It's a bold statement by Arsenal. Manchester United and Liverpool are saddled by multi, multi million pound debts by their buyers...here we have the most educated response from campaigning supporters [that] clubs should be owned by their fans or should at least recognized as institutions for the fans and not just directors or people who have bought the shares."
For Conn, English football can learn a lot by looking at their continental rivals in Spain and Germany, where fan involvement in the running of clubs is taken more seriously.
"In the Bundesliga, and with Real [Madrid] and Barcelona, a lot of the clubs across Europe, are sporting clubs, associations," explained Conn. "Here [in the English Premier League] it is unheard of, but it is just the way things were years ago and is the natural constitution for members' clubs not to be commercial companies."
The example of Spain -- where clubs like Real Madrid and Barcelona are run as associations with one member, or socios, having one vote -- and Germany -- where the Bundesliga operates the 50+1 rule to prevent any more than 49 percent of a club falling into the hands of a single person, prove you can be successful on and off the field.
Some argue that these models, as well as being alien to Britain's political and economic culture, don't actually work.
"It has to do with legal systems and freedom of association; in Europe since Roman times you were not allowed free association without the permission of the state [and] football clubs were seen as potential vehicles of rebellion; the state wanted to control them," explained Professor Stefan Szymanski, co-author of Why England Lose and Other Curious Football Phenomenon Explained.
"In England, that changed with the  Glorious Revolution, the state stepped back. The strange issue was that if a club wanted to borrow money to, say, build a stand, it couldn't as it had no legal personality. So they converted into limited companies."
It is this differing culture, argues Professor Szymanski, that led to clubs in Britain being run by boardrooms and not fans.
"We've had limited companies running football clubs for 120 years. Who owns these clubs has changed... but the experiences of supporters' trusts has been quite patchy. Take Notts County [the oldest professional football club in the world]. The supporters trust did more harm than good and nearly bankrupted the club [when they had a chance to run it]."
In recent years English football has experienced a financial revolution, powered by huge broadcasting contracts, that have attracted foreign owners from the UAE, the U.S., India, Iceland, China and Russia.
Attendances have steadily risen since 1992, but so have ticket prices and dissatisfaction from fans who feel they are being priced out of what was traditionally seen as a working class sport.
And whilst fans point to the success of Germany and Spain in melding sporting success with fan empowerment, professor Szymanski believes their flaws are overlooked.
"It's the British capitalist model, that is red in tooth and claw, versus the German semi-cooperative model -- you can discount the Spanish as a league model as it only applies to two teams," says Professor Szymanski.
"[England] raises far more money and are far more successful. Germans say they have higher average attendances but they play more games. They have a population of 80 million and should be way ahead in attracting players and fans. English fans pay three times more, but the fans see a higher proportion of the world's best players."
There has also been some discontent within Germany regarding the way the Bundesliga is organized. Martin Kind, the chairman of Hannover 96, has so far unsuccessfully challenged the "50+1" rule in the German courts, arguing it is uncompetitive and easily circumvented by big clubs and their sponsors.
"It stops clubs from being on the same level," Kind told CNN. "In England, France, Italy, Spain and Russia, there is no "50+1". But in Germany there are two clubs out of that rule because they are owned by companies: Wolfsburg, which is owned by Volkswagen, and Bayer Leverkusen, owned by Bayer. The same clubs compete for the top six places, and these are the clubs who turnover $140 million plus per season."
"Look at us. We have a $70 million turnover per season and we don't make any profit. With that amount of money, we don't have any business or sporting future."
Supporters of the "50+1" rule will point to the current Bundesliga table, where the tops six features the likes of Mainz, Hoffenheim and even Kind's own Hannover 96 as proof that smaller clubs thrive under the rule.
But for Szymanski the true measure of success should be what happens on the field, and not by the number of fans in the boardroom.
"Bayern Munich got to the final of this year's Champions League final, yes, but it was the first German team to get past the quarter-finals since 2002," he points out.
"Which system is more successful? The English are 6-0 up."