12 2005, the Arbitral Tribunal declared well-founded in part the first payment and unfounded the three remaining payments, including the accessory claim. It therefore results that the award concluded that “[o]f of two aspects incorporated in the Operative Paragraph [Eight] of the Judgment [of the Inter-American Court], the Arbitral Tribunal consider[ed] that the first already had been fulfilled, [so that] on the date the petition was brought, Mr. Ivcher had already recuperated his rights as majority shareholder of [the] CLRSA, a situation that has not varied to this date.” 23. That in the fulfillment of the award referred to, the State emphasized that on December 22, 2005, it paid to Mr. Ivcher the sum of S/. 20’378,402.22 (twenty million, three hundred seventy eight thousand, four hundred two and twenty-two cents of new soles), which represents: S/. 12’131,743.00 for dividends left unpaid, US$ 931,021.00 for fees left unpaid, and S/. 5,044,878.00 for the loss of value of the company. The State highlighted that it did not cancel the interests generated for said amounts after the arbitral award, so that “[o]n the date of December 20, 2005, Mr. Baruch Ivcher Bronstein communicated to the Vice[m]inister of Justice that […] renounce[ed] to pay [them],” so that the Peruvian State “cancel[ed] the total of that ordered […] before December 30, 2005.” 24. That on the other hand, the State pointed out that “in none of the operative paragraphs [of the Judgments issued by the Court in this case] does there exist any regulation regarding the tax material, nor an authorization given to [CRLSA] to not pay taxes to the [p]eruvian State.” Therefore, the State alleged that the request of Mr. Ivcher in the sense that “he orders the Peruvian State to abstain from charging the taxes not only of the per[i]od of 1997-2000 but also the per[i]od of 2001-2003 referred to, […] configures an abuse of the right to the protection conferred [on him].” It fits to emphasize that if Mr. Ivcher also requested the arbitral award “[that] orders the Peruvian State to assume the costs of the tax debt generated by [the company] through the illegal administration of [the brothers Winter],” the Arbitral Tribunal declared “unfounded” said payment under three arguments: 1) “the tax debt [generated by the Winter Administration] did not directly affect the wealth of the plaintiff, nor of the company of which he was a shareholder, that did not participate in this process and for which achievement cannot attribute the effects of this Award;” 2) “[i]f the intention of Mr. Ivcher is to find a connection between the precarious tax situation of CLRSA and his personal wealth, which in reality would correspond to allege the loss of the value of his business,” that had been raised in this award, it would imply a duplicity of claims, and 3) “[t]he anti-legal acts attributed to the State did not directly cause […] that [the] tax situation of CLRSA had deteriorated before the Prosecutor, but also Mr. Ivcher pointed out [in his petition] this claim originated in the non-payment accumulated of the tax debt generated by the previous administration.” Notwithstanding, the Arbitral Tribunal “consider[ed] it necessary to refer to the possibility offered by Mr. Ivcher so that the Peruvian State assume the responsibility for the tax obligations previously indicated [through] a compensation,” highlighting that ‘[i]f [said] compensation to which Mr. Ivcher refers can operate or not among the reciprocal debts and credits that CLRSA ha[d] with the Tax Administration, this must be determined in a distinct instance from [said] arbitration.” In this sense, the State pointed out that the resolution of the arbitral process “[c]onstituted […] res judicata and [hence] rejects the intention to reopen said payment [about tax material] for the route of supervision of compliance with the [j]udgment[s] of the [Inter-American] Court,” “be[ing] unaware of the tax obligations of […] legal persons that have been part of the process […], or that correspond[ed] to previous or subsequent time periods to the administration of the [brothers] Winter.” In agreement with the State, “the [Arbitral] Tribunal accept[ed] the points [raised by Mr. Ivcher], after having analyz[ed] them and not finding a causal nexus, reject[ed his] tax