Tosefta seems to be suggesting that ANY oganization that does NOT fit the mercenary definition of article 47 can commit acts of terrorism and seek protection under article 44. However, and contrary to what Tosefta implies, NO government in the world grants such status to people who carry out acts of terrorism in the name of their organization. I'm not a lawyer, but perhaps this is because of article 43 which requires that such organizations have "an internal disciplinary system which, inter alia, shall enforce compliance with the rules of international law applicable in armed conflict." Since terrorist organizations, almost by definition, do not enforce such rules perhaps this is why NO government in the world extends them sanctuary under article 44.
U.S. weighs sanctioning Russia as well as China in cyber attacks (Reuters)
from the article: Abducted soldier's mother: Politicians seeking clout off our sons' backs