Transfer Pricing
1. Aufl. 2021
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10. Business restructuring/transfer of functions
10.1. Description of the facts
In 2019, watches of the SmartGaist brand were still produced in Germany by Zeitgaist GmbH. For economic reasons, these watches will only be assembled in Germany from 2020 onwards and the individual parts will then be produced by Zeitgaist China. Zeitgaist China will procure the raw materials and materials in its own name and on its own account. The know-how required for the production as well as the corresponding protected instructions will be transferred from Zeitgaist GmbH to Zeitgaist China. The production manager is also sent to China – at least for a certain period of time – in order to escort the setting up of the production in China and to guarantee that the same standards are established and subsequently adhered to. In doing so, Zeitgaist AG expects an increase in the cash flow (before tax) of EUR 15 mio for the Zeitgaist group from 2022 onwards, whereas no effect on the cash flow (before tax) is expected for the years 2020 and 2021 due to the initial investments and the relocation taking place during this period. However, the relocation will have an immediate impact on both companies:
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