JAR FCL 1.185 states:
JAR–FCL 1.185 Validity, revalidation and renewal
(a) An IR(A) is valid for one year from the
date of issue or renewal, or from the expiry date
of a current IR(A) if revalidated in accordance
with JAR-FCL 1.246(a).
(b) If the IR(A) is restricted for use in multipilot
operations only, the revalidation or renewal
shall be completed in multi-pilot operations.
(c) If the IR(A) has not been
revalidated/renewed within the preceding
7 years, the holder will be required to retake the
IR(A) theoretical knowledge examination and
skill test in accordance with Appendix 1 to JARFCL
1.210.
[Amdt.1, 01.06.00; Amdt.4, 01.09.05]
There is no specific mention of not counting ICAO IRs issued by non-JAA member states or the military. This addition is pure CAA. As the UK law is just as much about the spirit of the law as the letter, I'm sure the interpretation and additional clause won't hold water in a UK court. I suspect the Eurocrat who drafted the original hadn't considered the possibility as to me it reads for someon who has not maintained an IR of any sort over the past seven years.
There are a lot of us who this affects and we will be taking action. I imagine the CAA won't want this trouble prior to additional work created by the EASA implementation!