By applying the above ruling to the Company’s factual transactions, it could be considered that the revenue earned from the resale of the imported goods bearing the UNIQLO trademark and designs, is paid to the licensor – UNIQLO, and not accrue directly or indirectly to the seller – FRSG. Thus, the payment does not meet the definitions of proceeds under Article 9 (2) of the Ministerial Regulation no. 132 (B.E.2543), and therefore should not be included into the customs value of imported goods.