CAR 206.
Aerial Work.
CPL and AOC required.
Some years ago a PPL, in his own aircraft, photographed properties in Queensland. He subsequently sold some of the photographs.
CASA swooped and the matter went to Court.
The Court found the flight was in the course of or for the purposes of trade and conducted without an Aerial Work AOC.
They are not running charters and carrying people or goods for profit.
But they can not conduct their business and/or trade (and thus presumably make a profit) unless the three companies "charter" or otherwise use or operate an aircraft.
A number of years ago, Stock and Station Agents, country vets and flying mechanics were all considered fair game by DCA/CASA for operating without an Aerial Work AOC.