The 2008 Regulation is an enabling regulation and the devil is in the detail of the Regulations now published. If you look at Article 7 of the basic regulation it says:
The requirements of the second and third subparagraphs may be satisfied by the acceptance of licences and medical certificates issued by or on behalf of a third country as far as pilots involved in the operation of aircraft referred to in Article 4(1)(c) are concerned.
Unfortunately, this is covered in the draft cover reg.
Article 7
Third country licences
1. Without prejudice to Article 1, Member States may accept third country licences, including any associated ratings, certificates, authorisations and/or qualifications and medical certificates issued by or on behalf of third countries, in accordance with the provisions of Annex III to this Regulation.
...
ANNEX III
TO THE IMPLEMENTING REGULATION REQUIREMENTS FOR THE ACCEPTANCE OF LICENCES ISSUED BY OR ON BEHALF OF THIRD COUNTRIES
Annex III goes on to cover validations for up to 12 months, and conversions of PPLs. There is no generic "acceptance" of foreign licences for third-country operators.
When I made my earlier posts (before the opinion was published) I was thinking along the same lines as you. But unfortunately it looks quite explicit in the IRs.