I could be wrong, but I think the problem here is that this seems to not be done for the purposes of character development, but done for the purpose of titillation.
There are plenty of ways to film a scene in such a way that these issues wouldn't come up, so I'm unsure why the director wouldn't want to err on the side of making this less exploitive of the child, unless the exploitation was the goal.
Doesn't matter to me what the purpose is.
You got a 12-year-old doing a nude or semi-nude realistic rape scene.
That ain't right, on many levels.
And it appears that it may fall within the legal definition of sexual exploitation of a child.