Paco,
Trying not to be too pedantic!
1. JAR FCL was replaced by PART FCL in the UK in September 2012.
If Dally83's TK credits are running out in the next few weeks, he did the exams in June 2013 or July 2013, i.e. after PART FCL had been implemented.
So JAR FCL does not apply.
2. You need a CPL to get an ATPL issued:
FCL.510.A ATPL(A) — Prerequisites, experience and crediting (a) Prerequisites. Applicants for an ATPL(A) shall hold:
(1) an MPL; or
(2) a CPL(A) and a multi-engine IR for aeroplanes.
Therefore, the licence referred to in '2' must be a CPL.