Gidday Shawn,
In Oz, the AIP defines VFR as being:
:In VMC
:navigate by visual reference to ground or water when below 2000'AGL
:at sub-sonic speeds (rules out the R22)
but no mention here of a horizon. There used to be something about horizons under night flying rules, but a quick search didn't turn up anything about night flight - has it been taken out?