Davidgrant, thank you for your measured response. If your VLJ will only fly 400 hours in a year, it seems that you have two problems. The first is how to make a profit on 400 hours out of such an investment, and is no-one's business except yours. CASA rightly is not concerned with your profit and loss situation, unless losses translate to dodgy operational practices.
Your second problem should be a concern to yourself, your clients and insurers etc. How to keep your pilots up to speed with relatively few flying hours/sectors? Why not approach CASA with 'an equivalent level of safety' argument? Offer to send your pilots back to Flight Safety once per year for refresher training and a proficiency check in the simulator. Small operators (and even some quite large) tend to fall behind the times if they don't expose their training staff to outside influences. They often develop some rather quaint practices - reinventing aviation for the mere sake of it - or end up in a training time-warp by never updating procedures. Specialist training companies like Flight Safety gather information from many incidents, accidents and operators' service problems, so regular visits there can only be beneficial. Then, to satisfy the CASA regulation regarding two checks per year, offer to do a line proficiency check at the mid-year point in the actual aircraft on revenue operations. Make it over a minimum two sectors per pilot with two instrument approaches. Of course, keeping the emergency scenarios to question and answer and touch drills only. I recall the pertinent regulation uses words to describe the proficiency check emergency requirements rather loosely - as in 'of sufficient nature' etc etc.