Here's CASA's most recent response, dated 8 March 2023, to my 4 most recent questions dated 1 March 2023:
Thank you for your further email. CASA’s response of Enquiry: ENQ-22-156466 on the 28 February 2023 provided the following answer:
Scenario for question 7: I conduct a flight as PIC in an aircraft with a maximum seat configuration of not more than 6, including the pilot seat. I have 3 passengers. I am not remunerated for the flight. The flight is not advertised to the general public. I pay an amount of the “direct costs” of the flight that is at least equal to the amount that would be paid by each person if the direct costs were evenly divided by all persons on board. Angel Flight gives the passengers $150 to give to me to reimburse part of my fuel costs for the flight. Just to be clear: $150 is much, much less than 3/4ths of the direct costs (including fuel costs) of the flight in this scenario.
Question 7: Do you comprehend that the flight in that scenario meets the definition of one that is “cost-sharing”?
Answer 7: No, as CASA would regard the payment from Angel Flight through the passengers to be remuneration to the pilot for the flight. This is because the payment from the passenger is effectively being made through or by a third party. CASA considers that payment arrangements for a cost-sharing flight must be only as between the participants of the flight.
This answer would cover any of the scenarios referred to in your latest email.
This guidance is current at the time it has been provided, however may be subject to change over time or at the discretion of the policy holder.
If you require further clarification relating to this matter, please reply to this email.