By applying the same rationale of Situation 2 of the case study to the Company’s case, it could be considered that UNIQLO (“the licensor”) and FRSG (“the seller”) are related parties, and there might be reason to doubt that the payment constitutes proceeds of a subsequent resale in case there is an indirect payment to the seller. As mentioned earlier, no portion of the proceeds accrue directly or indirectly by the Company or UNIQLO to the seller. More importantly, the payment to the licensor is for the services supported after the importations of the goods into Thailand, not related to resale or use of the imported goods. Hence, the payment under the Agreement should not be considered as proceeds.