Transfer Pricing
1. Aufl. 2021
Besitzen Sie diesen Inhalt bereits,
melden Sie sich an.
oder schalten Sie Ihr Produkt zur digitalen Nutzung frei.
5. Supply of materials
5.1. Description of the facts
Raw materials and other supplies needed for manufacturing the watches (such as precious metals, other metals, leather, plastics, rubber, fabric, or ceramics) are procured in South Africa, China, and Germany.
5.1.1. Supply of materials – I.
Southern Cape Inc. (South Africa) supplies Zeitgaist GmbH with gold, platinum, silver, and diamonds. These materials are used by Zeitgaist GmbH in manufacturing Molexx branded watches. Some of the silver also is used for watches of the Fossa brand. Southern Cape Inc., therefore, also directly sells some of its materials to Zeitgaist Production S. N. C.
Southern Cape Inc. operates largely independently. It purchases the raw materials on its own, and then sells most of what it purchases to the two associated companies. In much smaller volumes it moreover sells the raw materials to independent third parties. In performing its trading functions, Southern Cape Inc. makes all relevant decisions with regard to the purchasing activity on its own, uses the supplier network it has created, and bears all risks associated with its decisions. Zeitgaist AG wants to ensure that high quality standards are maintaine...