EY Corporate Services Limited to advise for the amount of THB 400 million paid to AYCAL since AYCL is transferred back to AYCAL the tax official could views and challenges that there is no value for the rights. The acquisition of the rights by AYCAL was for no value which the amortization could be disallowed for tax purpose. However, the dispute on the deductibility of the amortization of the rights could probably be raised against the THB 1,500 million with the ground that AYCAL and AYCL are both subsidiary of BAY which is 30% owned by GE. AYCAL accordingly should prepare to defend its position in taking the amortization as tax deductible expenses. The tax official may strictly interpret the law to be only in their favor and deny the amortization for tax purpose in AYCAL.