This may have been lost in your inboxes, so I thought I should flag the below paragraph from ALC's email earlier today which is directly relevant to the conversation currently being had with S&M on the Thai transfer:
"Please note that it is necessary the Mr. Tanakhon transfers all his shares in Alstom Holdings (Thailand) to Alstom Holdings (France) at par value first. Then Alstom Holdings (France) will immediately transfer said shares to GE at the real transaction price. Although Mr. Tanakhon may transfer his shares directly to GE under Alstom Holdings (France)’s instruction, from a legal perspective, it is absolutely not advisable from tax point of view. As the real transaction price has to be declared in the share transfer documents, such price would become Mr. Tanakhon’s income and taxable in Thailand."
This would appear to be what local counsel is advising, although it would be wise to check this with your tax colleagues to ensure that the tax obligation is not simply transferred from Tanakhon to Alstom.