Firstly I do apologize for overlooking the impact for Seagate IHQ
Regarding to your process flow for Seagate IHQ consigned the ASICs to Calcomp. Vendor A is the ASICs owner until Calcomp pull the ASICs for assembly, the ownership will move to Seagate IHQ instead so Thailand won't any PE issue impact but Seagate IHQ might get another exposure from 7% VAT same as Seagate Thailand due to it's deemed as sale in the land concept.
However,I will consult with our tax adviser by tomorrow and I will respond you back as soon as possible.