No grey area...........
Whirly....suggest you look up the regs.....quite straight-forward I'm glad to say when it comes to classifications of private/commercial flight.
Read them in detail as getting miffed with seeing the CAA turning a blind eye to obvious violations - even when numerous experienced pilots report transgressions directly to CAA (N-reg Bell 'crashing' at York/Ascot and dropping off fare-paying pax)
In the same cat as pilot, commercial or private, hiring a helicopter to fly passengers at a reduced rate - not using anyone's aoc etc
Completely illegal, no grey area, absolutely black and white.
Trouble with such an operation is that you don't know who your passengers are talking too whilst waiting for you to turn up - they were actually bragging about the 'deal' they got and how some of their colleagues paid a similiar price to go by train!
The people I feel sorry for are the normal operators of the machine who get tarnished by this pilot's actions - even though it had nothing to do with them.