I think that some of the celebs lower down the sliding scale of fame are also tied into sponsorship deals.
So, for instance, if some of the towie lot are snapped in a particuar clothing shop (Zara) and it gets the requisite headlines, it's a contractual obligation met.
Or if Cheryl Cole is on the red carpet, then it's a kerching sponsorship deal for L'Oreal.
Films and the film industry have lots of different backers, who in turn have advertising deals to spin to the paper.
It's all a big Ker-ching for businesses big, massive, colossal and small.