The ATPL VFR was apparently introduced to cover pilots in Switzerland who had to fly heavy iron but who were not going to go IFR in that environment.
Here are the rules:
In JAR Amendment 6 (10) "the holder of a CPL(H) gained under previous amendments of JAR-FCL 2 up to and including Amendment 3 is credited with the theoretical knowledge requirements for ATPL(H)."
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