I don’t agree with how trading is limited but I can not see how anyone could say that the current trade system is p2w.
You must pay to be able to trade, as a precaution to gold sellers (that just so happens to actually work). And you can not trade silver or high value (NPC value) goods, so it’s literally just to transfer items between friends.
I don’t agree with it because if they remove silver trading, then trading itself doesn’t have to be limited to paid players, it can be open to all.
That being said, trading isn’t even something people would do to earn money in ToS. Each trade is 1 potential loss which is pretty bad, and mats/recipes have a 1 trade limit regardless.