Add BOI investment promotion strategy

Group B base activity (plastics) with non-tax package and machinery duty
exemption; CIT value engineered via solar/BESS, smart-and-sustainable
automation, and R&D merit measures; NEC/Lamphun regional angle; BOI
approval sequenced ahead of incorporation and machinery orders

docs/boi.md

@@ -0,0 +1,114 @@
+# BOI Investment Promotion
+
+The project will apply for promotion by the Thailand Board of Investment.
+Research snapshot from July 2026, based on the BOI Investment Promotion
+Guide 2025/2026 and advisory sources; BOI revises its measures roughly
+annually, so every scheme cited here must be reconfirmed at filing time.
+The exact activity sub-code needs confirmation by a BOI-registered
+consultant before the application.
+
+## The strategic picture
+
+Vinyl pressing is, in BOI terms, basic plastic consumer-goods manufacturing
+(Category 6, chemicals/paper/plastics), which lands in **incentive Group B**:
+no corporate income tax holiday on the core pressing activity, but the full
+non-tax package and machinery duty exemption. The tax value is engineered on
+top through the upgrade measures, where this project happens to be strong:
+
+- **Solar and battery**: the alternative-energy measure (Announcement
+  2/2568, April 2025, under the Smart and Sustainable Industry framework)
+  grants CIT exemption based on the solar investment. Eligible spend
+  explicitly includes PV modules, inverters, BESS and BESS inverters, and
+  mounting structures, capped at THB 12M/30M/40M of investment value per MW
+  depending on investment type. The planned Deye + Gobel installation
+  converts directly into CIT-exemption headroom.
+- **Automation and metrology**: the Smart and Sustainable Industry upgrade
+  measure (Announcement 15/2565, refreshed July 2025) rewards automation,
+  smart machinery, and energy efficiency, typically 3 years of CIT
+  exemption capped around 50% of the qualifying upgrade investment. The
+  automated presses, inline optical inspection, and stamper metrology are
+  the natural fit.
+- **R&D merit**: investing at least 1% of revenue in Thai R&D adds 1 to 3
+  CIT-exemption years and can lift the exemption cap. In-house mastering,
+  galvanics process development, and recycled-PVC work could be framed as
+  qualifying development.
+
+So the application is pitched on solar, automation, and technology content,
+not on "we press plastic discs."
+
+## What Group B still delivers (the core value)
+
+- **Machinery import duty exemption**: significant with the entire equipment
+  list imported (Germany, Sweden, USA, Japan)
+- **100% foreign ownership** of the promoted manufacturing company,
+  overriding Foreign Business Act restrictions for the promoted activity
+- **Land ownership** for the promoted operation despite foreign
+  shareholding, plus a small allowance for office/residential use; note the
+  privilege is tied to the promotion, which matters for the buy-vs-lease
+  decision
+- **Visas and work permits** via the One Stop Service, without the usual
+  four-Thai-employees-per-permit rule; relevant for foreign commissioning
+  engineers and the technical consultant
+- **Raw material duty relief**: exemption for export production (1 to 5
+  years, renewable) and up to 90% reduction for domestic-sale production
+
+## Requirements
+
+- Minimum investment THB 1,000,000 excluding land and working capital
+  (comfortably cleared by the first pressing line alone)
+- Debt-to-equity ratio no higher than 3:1, maintained for the life of the
+  privileges; plan the equity/loan mix for the machinery and solar capex
+  accordingly
+- Modern machinery and process expected; ISO/environmental compliance for
+  larger projects
+- BOI promotion does not replace the factory license (Ror.Ngor. 4),
+  hazardous substance registration, or wastewater permitting; the galvanics
+  effluent is the most likely regulatory friction point regardless of BOI
+  status
+
+## Regional angle: Northern Thailand
+
+Chiang Mai, Lamphun, and Lampang sit in the **Northern Economic Corridor**,
+which BOI promotes as a creative-economy base; a vinyl/music manufacturing
+story fits that narrative. Locating in the **Northern Region Industrial
+Estate in Lamphun** simplifies factory licensing and land questions and
+provides shared central effluent treatment, which helps the galvanics
+permitting. Legacy "Zone 3" incentive tables still found online are
+outdated; the current area-based add-ons for Lamphun/Lampang must be
+confirmed with BOI directly.
+
+## Process and timeline
+
+1. File via the BOI e-Investment system, then present the project at an
+   analyst meeting
+2. Decision: about 40 working days for projects under THB 200M (60 to 90
+   working days for larger tiers); roughly 4 to 6 months end to end to the
+   promotion certificate in practice
+3. Incorporate the company (if not yet done) and accept the certificate
+4. Import machinery within the duty-exemption window, commonly 30 months
+   from certificate issuance (extendable); the Newbilt/Pheenix delivery
+   schedule must fit inside it
+5. Reach full operation by the certificate deadline (typically about 36
+   months), with progress reporting, annual reports, machinery lists, and
+   the 3:1 debt-to-equity ratio maintained throughout
+
+## Sequencing consequence
+
+BOI approval comes **before** company incorporation is finalized and before
+any machinery purchase orders: duty exemption does not apply retroactively
+to equipment already imported, and the certificate defines the import
+window. The BOI application is therefore a dependency at the top of the
+project timeline, ahead of equipment contracts.
+
+## Open items
+
+- Confirm the exact activity sub-code and tier for vinyl/PVC consumer-goods
+  pressing (Group B assumption is well supported but not code-verified)
+- Confirm the live versions and per-MW caps of the solar and
+  smart-and-sustainable measures at filing time
+- Confirm current NEC/Lamphun area add-ons
+- Engage a BOI-registered consultant to structure the application so the
+  solar, automation, and R&D measures stack on the base promotion
+- Keep any future label/content/retail arm in a separate entity: media and
+  service activities carry different (and sometimes Thai-ownership)
+  conditions, and mixing them muddies a clean manufacturing application