18 the fulfillment of the eighth Operative Paragraph of the Judgment remains pending. 44. That, finally, the Court observes that the Arbitral Tribunal declared that “[o]f the two aspects incorporated in the [eighth] Operative Paragraph of the Judgment [of the Inter-American Court], […] the first h[as] already been completed[, 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.” In this respect, this Tribunal specifies that it corresponds to the Inter-American Court, and not to the Arbitral Tribunal, to declare the fulfillment or lack thereof of that ordered in the Judgment. Also, the Tribunal observes that the General Law of Arbitration then current does not permit the review of the merits of the present controversy at the judicial headquarters, meaning that at that moment Mr. Ivcher could not have challenged the result of the arbitral award in relation to the tax debt that was generated between August 1, 1997, and December 6, 2000 (supra Considering 32). Notwithstanding, the Tribunal reiterates that the fulfillment of that ordered by the Inter-American Court cannot be seen as conditional or limited by regulations of internal law (supra Considering 5). 45. That in view of all the aforementioned and in accordance with the eighth Operative Paragraph and paragraph 123 of the Judgment, it corresponds to the competent authorities of the State in this material to adopt the measures and procedures necessary to abstain from collecting those taxes, fines and/or moratorium interest generated during the illegal administration of the CLRSA between August 1, 1997, and December 6, 2000, with the goal of re-establishing the use and enjoyment of the rights of Mr. Ivcher Bronstein as a majority shareholder of the company, conforming to his position until August 1, 1997, and with the goal of guaranteeing that his right to personal wealth regarding said capital is not affected by tax debts generated by illicit acts of the State itself. * * * 46. That regarding the duty to pay Baruch Ivcher Bronstein an indemnity of US$20,000 (twenty thousand dollars of the United States of America) for moral damage and the return of the costs and expenses generated in the internal jurisdiction and in the international jurisdiction for an amount of US$50,000 (fifty thousand dollars of the United States of America) or its equivalent in Peruvian currency at the moment the payment is made, the State indicated that both amounts were paid, satisfying “[that] recognized by Mr. Ivcher Bronstein himself in [his] brief of October [6], 2005, presented before the InterAmerican Court.” 47. That Mr. Ivcher confirmed having received the payment of the respective amounts for indemnity for moral damage and the return of the costs and expenses, according to that ordered in the Judgment. 48. That the Commission observed that in agreement with that informed by the State and Mr. Ivcher, the obligation of payment of the indemnity and the return of the costs and expenses has been fulfilled. 49. That, as a consequence, this Tribunal declares fulfilled the state obligation consisting of paying Baruch Ivcher Bronstein an indemnity for moral damage and the