I always understood it was your first definition too.It just depends on how you define zero degrees. I always used to say toe-in if the speakers were at any angle inward from perpendicular to the wall behind them.
Then Erin Hardison defined it in his reviews as any angle inward from the speaker facing directly at the listener.
I’m not aware of any published standards with a definition. But I’m not overly familiar either the standards on speaker measurements.
Then I began to read ‘toe-out’ and realised it couldn’t possibly mean angled towards the side walls…!!