I’m inclined to think the interpretation is right.
Labor Development Administration Letter No. 11005117021
The Ministry of Labor’s Labor Development Administration Letter No. 1070507378 dated November 27, 2017 states that as long as it does not affect the employment opportunities of nationals, it does not fall within the scope of Article 43 of this Law.
It lists the activities not within the scope of this Act and foreigners do not need to apply for a work permit.
It is divided into 5 categories: business activities, course internship or training activities, auxiliary service activities, general social activities and other activities that are not for the purpose of providing labor services to anyone in the country and do not hinder the employment opportunities of local people. The relevant categories are listed Appearance is the essential element for judgment.
If the behavior is not within the scope of the enumeration in the Ministry of Labor’s letter of explanation dated November 27, 2017, it should still be determined in accordance with the purpose of this law and the specific facts of the individual case.