Should be an okay counter formation, i've seen some people use 4-1-4-1 in tough leagues aswell- thoes work fine too :P
How about 3N-2W-3N-2? I find it a good counter formation too :P It's up to your team and what they'r quality and performance for certian roles are.
Check you'r strongest opponent's formation and see if they attack thru middle or flanks, once u've figured out that you can build ur standard counter formation w/o having to change it much.
I personally never got in a tough league so i couldnt test thoes formations with my main team but my alt teams did pretty good job with 3-2-3-2 winning the cup and league in 1 season w/o spending a penny for tokens