17 between September 5, 1997, and March 30, 2001, and that, as a consequence, had ordered the restoration of the legal activity and the administrative structure that the company had before the violations of human rights that the State committed against Mr. Ivcher. The Court understands that such measures tend toward the re-establishment of the situation prior to the declared violation. 39. That notwithstanding the aforementioned, Mr. Ivcher and the Commission alleged that this aspect of that ordered in the Judgment cannot be fulfilled until the State abstains from collecting the tax debt generated by the CLRSA through the illegal administration of the Winters between August 1, 1997, and December 6, 2000, and consider that said debt is one of the direct consequences of the declared violations in the present case. 40. That, in this sense, this Tribunal has noted that Mr. Ivcher requested the Arbitral Tribunal “[that] orders the Peruvian State to assume the cost of [said] tax debt,” and that he declared unfounded “said payment, so that he considered, among other reasons, that “the tax debt [generated by the Winter Administration] did not directly affect the personal wealth of [Mr. Ivcher], but that the company of which he was a shareholder,” (supra Considering 24). On the other hand, Mr. Ivcher presented a request for constitutional protection on this point that was rejected on May 20, 2008, by the Constitutional Tribunal of Peru (supra Considering 25) so that, according to such Tribunal, “the constitutional protection process is not the way to execute the judgments of the Inter-American Court.” Also, the Constitutional Tribunal pointed out that the result of the Arbitral Tribunal had the effect of res judicata and that the Judgment of the Inter-American Court was declared in favor of “the personal rights of Mr. Ivcher, not of all the members that made up the [CLRSA], in favor of which the debt relief from the tax debt is now requested.” 41. That if in the Judgment, this Court issued to “the competent national authorities” the fulfillment of that ordered in the eighth Operative Paragraph, it is understood that the same are not at liberty to resolve the issue in a contrary manner to that determined by this Tribunal in the Judgment. In this respect, the Court remembers that established in paragraph 123 of its Judgment, in the sense that, contrary to that resolved by the Arbitral Tribunal, the participation in the shareholder capital of the company effectively constitutes the good regarding which Mr. Ivcher has the right of use and enjoyment, in light of the American Convention. Therefore, by the means in which said shareholder capital appears to be affected by the tax debt generated between August 1, 1997, and December 6, 2000, by the administration of the Winter brothers, who took power of the company illegally with the acquiescence of the State, also will appear the affect of the right to property of Mr. Ivcher for the acts imputable to the State. 42. That as also pointed out previously (supra Considering 38 and 41), it results that at the beginning of the month of August of 1997, the moment just before the violation of the rights of Mr. Ivcher Bronstein, the CLRSA did not have any tax debt with the State. It was only due to the illegal management of the company that generated the material tax debt of the present controversy. 43. That, therefore, the Court considers that the tax controversy pending resolution impedes Mr. Ivcher from being able to be fully restituted regarding the use and enjoyment of his right as a majority shareholder of the CLRSA, just as he was until August 1, 1997, due to, according to that provided previously, the debt which affected the capital of the company, regarding which Mr. Ivcher has a right to property as a shareholder. In this way,