I'm confused, there are lots of if's and what's in this thread. It's very vey simple.
if the majority/key decisions of your companies are made in Thailand, then they are simply Thai companies from a tax perspective. Is this really enforceable once you go there and see how things work on the ground? no. can you get a way with it? probably. Is it illegal if you don't report them? yes. even if you don't remit the money? also yes!
if you have a proper structure offshore and have offices, staff and key management decisions are made abroad (And you can prove that), and then︀ you remit money the next year to Thailand, you are good to go. you can︁ have cheap substance in Romania or Serbia, but the taxes there are different beast all︂ together. Dubai is also an option, and more straight forward but a little bit expensive.︃
regarding the dutchman case, we can't single out a huge case like this and make︄ an example out of this to point fingers at Thailand, the guy's history is filled︅ with troubles and controversies and he had strange connection in LATAM, overall not a great︆ example.
I live in Labuan part of the year (one of my holding companies is︇ there), and it's been great, I still dance around sometimes with the local authorities, but︈ my lawyers take care of things. But overall, it's been pretty good and I have︉ access to top tier Malaysian and Singaporean banks. Still, they can change Labuan rules and︊ f it up again, So I' looking into other options. probably Singapore this time.
But yeah enough of my rambling, bottom line just go to Dubai and call it a︋ day.