Hello paco, i agree with all that!!
But this part
"
Since the introduction of the ATPL(H)(VFR), the IR(H) and the ATPL(H) theory have their own validity period from the day the exams are successfully completed - 36 months for the CPL(H) and IR(H) and 7 years from the last validity of an IR entered in the licence, or a helicopter type rating (for helicopters).
"
which is in
JAR–FCL 2.495 Acceptance period
says that who got their ATPL credits via a CPL(h) exam will only get those credits valid for 36 months regardless of the rest.
I have done the tipical CPL(H) + IR(H) exams in 2008 and 2009 and the license in 2009, and got my first IR(ME) in less than 36 months,
So the credits are valid only for 36 months.
Since i didnt get ATPL(H) due to lack of flight hours in those 36 months, my ATPL(H) credits are gone.
Is this the real understanding of this? And may be this the reason for some countries not giving the credits??
Thank you for the help!