I agree with Seat OA. The problem is that Subpart Q is not precise enough:
In the Subpart Q definition of Break is that it is part of Duty (not FDP). My company uses this definition in Split Duty to prolong FDP for half of the Break, but without counting Break in FDP, so we end up with extension of 150% of the Break.
Also some things are left to National Authorities, which, if not good (like mine) leave many things open to interpretation.
I would like to know if there is an e-mail with JAA/EASA where I can ask for interpretation of their regulations (like I do with Boeing).