Transfer Pricing
1. Aufl. 2021
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8. Cost Sharing Arrangements
8.1. Description of the facts
As the group’s headquarters, Zeitgaist AG houses certain centralized administrative departments such as staff department, HR department, financial accounting, bookkeeping, tax department and information technology. The HR department, financial accounting, bookkeeping and tax department are responsible centrally for all units belonging to the group. In the individual local companies, there are only a few, if any, people working for these departments.
For example, Zeitgaist AG employs 12 people in its tax department. Expenses for personnel and other expenses amount to EUR 2,104,125; expenses for the use of external consultants are not included in this figure. The breakdown by salary segments is as follows:
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Salary segment | Range (in EUR p. a.) | Number of employees |
Lower | 40,000 – 55,000 | 5 |
Middle | 80,000 – 105,000 | 4 |
Upper | 140,000 – 275,000 | 3 |
The tax department works primarily – to the extent of 60 % – for Zeitgaist AG. The employees are required to allocate their hours to the individual companies so that it is possible to determine to what extent someone has worked for which company. For example, Zeitgaist Marken AG claimed 5 % of total working ho...