Aren't all CPL+IR pilots with enough PIC, multi-engine multi-crew time (etc etc) automatically ATPL holders? Lasors G3.3 refers:
The holder of a JAR-FCL CPL(H) and IR(H) satisfies the knowledge requirements for the issue of an ATPL(H).
In other words, as the knowledge requirements are satisfied, once all the practical requirements are met, the holder gets a free upgrade to ATPL.
That is how it was portrayed to me by the CAA, anyway.