FFF - your knowledge of JAR-FCL is amazing! While I did my Night Qualif. in Florida (just after the JAA PPL skill test, and before the licence was actually issued by the CAA on my return), I can confirm that the French rules (and undoubtedly the Spanish ones too) are the same as the British ones... It's all JAA. A CAA-issued JAA licence is fine to fly an F-reg a/c in France (that's what I do), the only requirement is, like in any other flying club, to be checked out before going solo.
Cheers