Transfer Pricing
1. Aufl. 2021
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1. Introduction – the arm’s length principle
1.1. Description of the facts
Zeitgaist multinational enterprise group. Zeitgaist AG has its headquarters and management in Frankfurt am Main (Germany). It has several subsidiaries and branches abroad and is the ultimate parent entity (UPE) of the multinational enterprise group (MNE group) „Zeitgaist”. The MNE group specializes in particular in the manufacturing and sale of watches. It also produces and sells accessories, such as bags and belts, to a small extent. With its products and 1,740 employees, it generates a consolidated turnover of approx. EUR 1 billion.
Product range. The product range of the MNE group includes watches from three different brands, each of which is aimed at a different customer target group.
Watches. Under the brand „Fossa” watches are sold in the low budget range up to approx. EUR 1,000 per piece for everybody. This brand has been known for years and is registered in Switzerland. The brand is legally protected worldwide.
Chronometer. Under the brand name „Molexx”, chronometers are sold in the luxury segment from EUR 10,000 and above per piece for rather wealthy people who want to treat themselves to something spec...