Any advice on ACCA practicing certificate?

I am ACCA member with more than ten years experience in industry in different countries. The last two and half years were in UK.

Now I decided to work and live in UK. But I like to work as freelancer than employed. Therefore set-up my own consultancy company assisting companies in sorting out financial procedures, budget preparation, internal contorls etc. While providing these services, I get request from my clients for outsourced PAYE services, VAT services and Internal Audit and Risk Managment Systems Review. A year ago I requested ACCA's clarification whether I need practicing certificate to provide those servies and got written evendence that I do not need any as long as I am not certifying documents to third party or provide tax or other consultancy for which I need practicing certificate.

However now after a year I requested other clarification and noted that I still need practicing certificate to provide PAYE, VAT and Internal Audit. None of these fall into ACCA's definition of public practice. When I spoke to someone from ACCA over the phone he repeated the same thing that I do not need any practicing certificate.

My question is does PAYE, VAT and Internal Audit fall as public practice?

Thanks for the advice.

Eden

Eden Fissaha