Ahhhh, I see said the blind man. Thought you were debating the affirmative to paid scenics on an RAA ticket..
CAO95.55 is the example I'll use. As you know, it lists the parts of the act and regulation we have been permitted an exemption for.
Sec 3.1(f) Gives an exemption to CAR 1998 reg 210 to advertise as far as; "flying training to qualify for a pilot standard specified in the RAA Operations Manual is concerned;" I'm not certain if, or how they would be getting around doing TIFs as joy flights or for the requirement to hold an AOC to do so.
CASA, like any government department, is chockablock full of bureaucrats and toss pots and real easy to get negative toward.
The problem is that there's just as many punters on our side of the fence trying to circumvent the limitations imposed on our recreational cert. or of a PPL for that matter.
I'll keep digging to try find a better answer, but don't hold your breath waiting for it.....