I don't think they are. The club coefficient seems to be the greater of your club coefficient or the league coefficient.
So a new club in Europe will default to the country coefficient. Clubs whose own coefficient is less than the national coefficient also default to the national one (see Southampton, West Ham, Burnley and Everton) But Milan and Qarabag have both earned their 19 points, based I think off the rounds they reached in Europe rather than the wins/draws they got.
Though I don't understand why Liverpool scored 29 points for winning the CL last year, while Barcelona and Chelsea scored 30 points, as did Liverpool last year when finishing runner-up in the CL.
El-Pietro will explain all if he pops by!
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