That interpretation of "DME" has been thought of before by greater brains than myself but I don't know if any European authority has ruled on it.
The FAA has rules that permit an explicit substitution of a DME (and other things) with an IFR GPS, and my guess is that since they felt the need to formalise such a substitution then others would have to also (or not, as the case is universally in Europe).
Switzerland allows an IFR GPS to substitute for an ADF but that's the only case I am aware of
http://www.ead.eurocontrol.int/eadba...2005-05-12.pdf