What about the employees of an American company currently based and living in Europe flying N-reg jet aircraft. Do they have to obtain an EASA ATPL?
That's an interesting one...
Where would the 'operator' consider itself to be based?
Gold plating, I would venture to suggest....
The whole issue of whether an FAA to EASA IR holder needs an ATO to recommend them for test seems to have got muddled by the CAA, there shouldn't in theory be a need for one but once again in their infinite wisdom the CAA seem unable to reconcile the new rules with their old way of doing things...
In practice I suspect most FAA IR holders will go to an ATO because it is the ATOs that know all about the EASA IR test and will be best placed to prepare the candidate for it.