Interesting question.

As far as the Universal Counting Method is concerned...

Although Article04 states:
Only the component members of a gestalt team count.
I'd say that this is negated by Article05 and Article17.

Article05 states;
Individual combiner robots count separately but multi-in-1 components do not.
Devastator's individual parts are like "multi-in-1 components," much like say the two halves of the Duocons or say Skysaur, Landsaur and Seasaur - the three individual components of Magmatron. Furthermore they lack robot modes.

Furthermore, Article17 states:
All transforming movie Transformers count but non-transforming movie Transformers do not.
While these vehicles are able to combine, I'd say that they do not fall under the conventional definition of "transform" as far as Transformers action figures are concerned.

I might bring up this discussion again in the UCM Discussion thread after RotF has come out. But for now I'm just keeping it in this section for spoiler reasons.