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.1)
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 special. This very traditional and classic brand was registered at the German Patent and Trademark Office (DPMA). The trademark is legally protected worldwide. The movements of these chronometers have been tested by an official test centre to prove a defined accuracy.
Smartwatch. Under the "SmartGaist" brand, customizable smart watches are offered for those who want to keep up with the time. This is a new brand which was only introduced to the Zeitgaist group's business model four years ago. The brand was registered in Switzerland. The brand is legally protected worldwide. Tab. 1: product range Zeitgaist group
Companies of the Zeitgaist group. The Zeitgaist group includes the following entities and permanent establishments (PEs):
Zeitgaist AG (Frankfurt, Germany, Headquarters (UPE) - Administration centre and sales) PE in Paris (France, sales) PE in Dubai (United Arab Emirates [UAE], sales) PE in New York City (US, sales) Zeitgaist GmbH (Glashütte, Germany, Production and manufacturing) Zeitgaist Marken AG (Zurich, Switzerland, trademark administration) ScienceLab AG (Basel, Switzerland, concept, design, research and development) Southern Cape Proprietary Limited [Pty Ltd] (Cape Town, South Africa, raw materials and supplies) Zeitgaist Commodity Wholly Foreign Owned Enterprises [WFOE] (Beijing, China, raw materials and supplies) Zeitgaist Distribution Incorporated [Inc.] (Washington, US, distribution) Zeitgaist Europe besloten vennootschap [B.V.] (Rotterdam, Netherlands, distribution) Zeitgaist China (Beijing, China, sales and production) Zeitgaist Producción Sociedad de Responsabilidad Limitada [SRL] (Mexico City, Mexico, production and manufacturing) Zeitgaist Production Private Limited Company (Yangon, Myanmar, production and manufacturing) Zeitgaist Production Societate in nume colectiv (S.N.C.) (Timesoara, Romania, production and assembly) Zeitgaist Inc. (Palo Alto, US, Data Analytics, Research and Development) Zeitgaist Finance Limited Liability Company [LLC] (Singapore, Singapore, financing) Schmiermittel AG (Geneva, Switzerland, manufacturer of oils, greases and epilamens) Fig. 1: Overview Zeitgaist group Fig. 2: Overview Zeitgaist group - Europe Tab. 2: Overview of the MNE group's functions
Profit and loss statement, consolidated balance sheet and extract from the CbCR. The following profit and loss statement and consolidated balance sheet comprise all business units. The country-specific report contains only the entities and countries listed above.
Tab. 3: Profit and loss statement Zeitgaist group Tab. 4: Consolidated Balance Sheet ...
