If a student is paying training rate for a licence, then surely that is flight instruction
Then how do you differentiate between ground instruction and flight instruction? Does the aeroplane have anything to do with it or is it just because payment is made?
Like most European rulings they were put together with little thought, we should be used to this by now.
What it means is down to what the NAA issuing the licence allows, even they are probably not capable of making a rational decision, its just rules, tick enough boxes and you win a prize at the end.
As it probably wasn't written in English originally, nobody can really tell what the original committee intended if indeed they did any more than rubber stamp the NPA proposal without giving it any great thought.