Fromn the FAA's part 61 FAQ:
QUESTION: The particular question is whether a flight instructor who passes a flight instructor practical test (for initial issuance or a CFI rating addition or for a reinstatement) is or is not exempt from needing a §61.56 Flight Review for the next two years, since the reg. specifically says PILOT proficiency check.” §6l.56 d - allows this exemption for a person who has"... passed a PILOT proficiency check.." not needing to accomplish a flight review for the next 2 years.
ANSWER: Ref. §61.56(d); If the examiner also evaluates the applicant’s piloting skills then YES, “. . . a flight instructor practical test (for initial issuance or a CFI rating addition or for a reinstatement) . . .” would meet the requirements of a §61.56 Flight Review. However, to make sure the applicant gets credit for successful completion of the Flight Review, the examiner should record that the §61.56 Flight Review was satisfactorily completed in the applicant’s logbook.
§61.56(d) states:
(d) A person who has, within the period specified in paragraph (c) of this section, passed a pilot proficiency check conducted by an examiner, an approved pilot check airman, or a U.S. Armed Force, for a pilot certificate, rating, or operating privilege need not accomplish the flight review required by this section.