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That's a very interesting and novel idea
As the Twintake proves, there's no doubt that more 'cold' air (fresh air might be a better description) can be sucked in from around the headlight area and it avoids the water ingress potential when the intake is at foglight level.
However, although I'm no expert, my gut feeling tells me that it might not get through MOT due to headlight beam requirements. Certainly this mod couldn't be applied to sealed Xenon units.
Thinking aloud, it would appear to significantly add air flow to a GTI with ITG tubular intake.
Are you thinking of this mod as an extra air intake to the normal upper grill front?