In case the Lender is a Thai company, the lending of money from the Lender to the shareholders of the New Company by providing a grace period of paying interest for 3 or 5 years in the Loan Agreement and such loan being paid on demand by the Lender might raise suspicion of the Revenue Department of Thailand. We are of the opinion that the lender of the loan should be another affiliated company of CP Laos. A BVI company is recommended.