In 2010, we engaged EY to help us on form D issue, we submitted the ruling request to DFT with explanation of third country invoicing concept. (you can see it in Guan Hoe e-mail attached file)
Finally, DFT gave us the ruling, which mentioned that Form D can be applied with third country invoicing concept under AFTA but the eligibility to use the preferential duty depended on a consideration of Customs authority in the destination country. In this case refer to Grohe Pacific invoice.