My migraines are mostly of the "silent" variety (blind-spots, visual disturbance, scintillating scotoma, confusion, aphasia), sometimes there's significant pain, often not. There seems to be some connection between the migraines and ME/CFS (my collapse was precdeded by several months of increased migraine severity and frequency), but there is a strong distinction between the more acute elements of each. Even where symptoms overlap, the migraines follow a definite and consistent progression, whereas PEM seems to go up and down and come and go (to say nothing of the different durations). That said, you're absolutely right that some of vestibular symptoms, the particular nature of the motion-sickness/nausea, and sensory sensitivities can all feel very, very similar - including both the exacerbated forms that arrive with PEM and the constant forms that never really leave.I used to describe PEM as a migraine-like state without the headache. Unfortunately the neurologist just looked at me like I was crazy and sent me away instead of trying to see if common migraine meds would provide any relief for feeling this way.
Migraine is a very good comparison because PEM to me involves a lot of vestibular symptoms (just looking at a simple video on Instagram will trigger instant motion sickness) which don't happen outside of PEM to me. Then there's the nausea, low appetite, slow digestion but also just feeling pain everywhere (but the head and legs for some reason), worse sleep issues than usual. But I never had any aura and the ocassional headaches I get are very mild.
Some of the cognitive difficulties can be pretty close as well, though they are excrutiatingly difficult to describe.