Transfer Pricing and Intangibles

1. S. 52Case study

1.1. Case facts

This case study deals with the fictitious “C’est Si Bon (CSB) Group”, a multinational enterprise (MNE) established in the early 1960s and currently operating in more than 40 countries with nearly 6000 employees worldwide. CSB owns leading brands and technologies in the nutrition, health, and wellness industry sectors. The group is producing and selling brandedover the counter (OTC) health products to wholesalers, drugstore – and supermarket chains, via individual non-medical practitioners as well as online. CSB’s product portfolio comprises vitamins, minerals, edible oils, and other nutritional supplements. The group uses a centralized business model in order to achieve operational excellence with high effectiveness in terms of time-to-market, operational efficiency in supply chain and distribution, and cost savings.

CSB SE is the parent company of the group with their central management and control functions headquartered in Belgium. The main R&D, marketing and sales functions as well as international brand management are also located at the headquarters. As a result, CSB SE is the owner of all of the valuable technology and marketing intangibles in the ...