Lot of things have changed yes.
But i understand you reside in Thailand (Territorial).
As long as you are not actively involved in the operations (i.e physically directing all the time) then like domestic, you are only taxed on income, in this case remitted income.
Thailand (as per my conversation - and my real concern in Sep) is not interested in taxing companies overseas whereby the Director/Majority shareholder etc resides in Thailand, that's not currently on the cards, as long as the business doesn't do business in Thailand.
If you have some local staff for the overseas company then they have to become 3rd party contractors (not employees) - Self Employed or their own LTD.
And of-course you can't sell into Thailand or do business inwards of Thailand.
Correct.
Though... there's ways around that. Credit Cards are debt... so there's contention for pushing that through the court system (pretty sure it will be by 2026).
Another possible loop-hole that will have to be pushed through the courts is "GOLD" in Thailand Gold is tax exempt.
You could import into Thailand gold holdings and then liquidate domestic (this could be cheaper than tax).
You could possibly also liquidate gold holdings overseas and remit the fund and when it comes to declaring 'gold sales' which are exempt whether they would recognise this is external and tax free or
income tax charged is the contentious point for the courts.
I would love to move back to HK, alas i now have two kids and a third on the way so it's not practical.