I hope you will accept that someone who is operating an aircraft - particularly
as "sole manipulator of the controls" during Take Off, Approach and Landing
is acting as a Pilot.
Show me the regulation where it says that during the flight, only "a pilot" may handle the controls, or that somebody handling the controls is (for the purpose of the regulations) considered "the pilot". Either a generic rule or one that is specific for take-off and landing. I'd be most interested, but I have never come across such a rule.
I regularly let my passengers (some of which are well below the legal age to be pilots anyway) handle the controls. That doesn't make them pilots. That doesn't compel them to write anything in their logbooks. And there is no limitation anywhere that I know of, that would prevent me from letting them do the take-off or landing as well. As passengers. And as sole manipulators of the controls.
(Well, that last statement is not quite true. I know of one specific aircraft where the POH directs you to remove the controls from the RHS if the RHS is occupied by a passenger. So you would not be flying according to the POH if the passenger would handle the controls, as his controls should not be there in the first place.)
And to further reinforce my point, the ANO always talks about "pilot" in almost every article. Sometimes made more specific by terms such as "pilot in command", "pilot flying" and so forth. This suggests a person who holds a valid and current pilots license for whatever class or type of aircraft we're dealing with. But in the currency requirements all of a sudden the whole word "pilot" has disappeared and all we are left with is "sole manipulator of the controls". Why would that be, do you think?
ANO Schedule 7, Part A, section 1, subsection 1, Private Pilots License:
(2) The holder may not—
[...]
(g) fly as pilot in command of such an aeroplane carrying passengers unless—
(i) within the preceding 90 days the holder has made at least three take-offs and three landings as the sole manipulator of the controls of an aeroplane of the same type or class;[...]
(This is from section 1, "United Kingdom Licences". But the wording in section 2, "JAR-FCL licences" is the same.)
Anyway, the ANO has been superseded (or will be superseded shortly) by EASA regulations which are worded differently, so the whole discussion will be moot then.