That's actually not coreect - here is how we see it:
After the introduction of the new reduced CPL(H) theory course, the combination no longer equates to ATPL(H) theory. To gain the ATPL(H) with IR if you have a post-Amendment 3 JAA/EASA CPL(H), you must take 12 exams out of the 14 required - you will be exempt POF(H) and VFR Comms. If you just want the ATPL(H), you are exempt air law as well.
However, it is our opinion that, if you have a CPL(H) issued under JAR FCL Amendment 3, that is the equivalent of the ATPL(H)(VFR) in terms of theoretical knowledge - paragraph 2.050(b)(10) refers. This credit was carried over into Part FCL. In addition, Article 4(1) of Commission Regulation (EU) 1178/2011 refers to JAR compliant licences being deemed to be Part FCL licences. The legal definition of "JAR Compliant" licence is in Article 2, which refers to licences, ratings, certificates, authorisations and other qualifications issued or recognised by a State, reflecting "JAR and procedures". We interpret this to include ATPL(H) TK credit.
Phil