Valeo Japan situation: According to Japan tax regulations in the case of transfer of goods, the place of supply is where such goods are located (Consumption tax law basic circular 5-7-10).
Since the tooling remain in Japan, the sale would be subject to JCT. That is, Valeo Japan has to charge and collect JCT to GM Thailand (and remit to Japan tax authorities).
GM Thailand situation: for information, there is no registration system in the JCT Law.
GM Thailand has to determine its JCT position (i.e., a JCT taxpayer or a JCT exempt enterprise) by himself ( and depending on its own situation claim a JCT refund to Japan tax authorities - Consumption tax law article 5, article 9-2, article 22, article 57 ).