Swatch Group is one of the world’s leading watchmakers. The
group owns a stable of 17 watch brands, including Breguet and
Omega. Just as many other multinational companies do,
Swatch devotes considerable energy to devising tax arrangements
that minimize its overall tax burden. In general, such
practices (sometimes referred to as international tax arbitrage)
are perfectly legal. However, in the summer of 2004, two
whistleblowers who had left the company were asking U.S.
tax authorities to have a closer look at Swatch’s tax policies.
They had built up their case with a stash of internal e-mails and
company documents