I would suggest if your intention after catching the fish is to sell them then it is a Commercial Operation.
Simple definition, private ops are those you do for you alone, no intent to make any gain from them nor intend to commercialise any thing that is involved, including pax, cost share is just that equal shares for you and the pax, or you cop the majority and a portion is subscribed by the pax, but not as any form of intent nor with pax unknown to you.
206 is very narrow regulation, no wriggle room at all.