True, there is a loophole in the way the rules are worded. However, without very good knowledge of the aircraft, its systems and emergency procedures etc, anyone attempting the ATPL test is setting up for failure. Although the content of the test appears similar to an IPC there is more emphasis on overall management of the whole operational scenario; whereas in the past candidates for the old CIR tended to be assessed merely on flying to the tolerances.
If money is available probably the best way would be to do a type rating and combine the final check ride with the ATPL test. Usually at the end of a type rating course the candidate is at a peak - in the simulator at least.
Another potentially cheaper (but still not cheap!) angle to explore is to use something like a King Air. CASA have indicated that they are prepared to accept such aircraft, but only if proper two pilot procedures have been developed.
Again, without good aircraft knowledge and well-practised multi crew procedures any candidate is likely to be disappointed.