Thaksin’s tax manoeuvres still baffling 11 years on

It is perhaps only of academic interest, but the way Thaksin Shinawatra chose to structure the sale of his block of Shin Corp shares that were parked offshore in 2006 is still a matter of curiosity. Creating the tax liability that arose from the off-market sale well below the market price is something that an astute tax planner would surely have advised strongly against. Another interesting question is, why did Thaksin want to repatriate the shares to Thailand immediately before the sale, having presumably gone to some trouble to get them offshore in the first place? This meant that the proceeds from the sale had to be paid in Thailand where, as bad luck would have it, they ended up subject to the Supreme Court’s seizure order. 
It seems very likely that the intention was actually to complete the transaction of that block of shares offshore and keep the proceeds safely overseas. An obvious way to do this would have been to leave the shares with the British Virgin Islands shell company, Ample Rich, and persuade Temasek to buy the company with the shares still in it. Some sources have alleged this was indeed tried, but Temasek refused to play ball, since despite having no qualms about its apparent violation of Thai foreign ownership restrictions, the company demanded the transparency of having the transaction reported at the tender price through the Stock Exchange of Thailand. 
George Morgan