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UBI Banca Group

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million were recognised through profit or loss in 2011, of which €15.9 million had already<br />

been recognised as at 30 th June 2011.<br />

Impairment losses of euro €15.3 million were also recognised during the year on non<br />

significant share holdings and also on units held in OICRs (collective investment instruments).<br />

Realignment of values for tax purposes relating to goodwill and other intangible assets<br />

Paragraphs 12 to 15 of article 23 of Decree Law No. 98 of 6 th July 2011, converted into Law<br />

No. 111 of 15 th July 2011, containing measures for financial stabilisation, allows values for<br />

statutory accounting and for tax purposes relating to goodwill and other intangible assets to<br />

be realigned. More specifically the legislation in question allows, in accordance with the<br />

principles of Law No. 2 of 28 th January 2009, the recognition for tax purposes of higher values<br />

attributed to controlling interests acquired through extraordinary transactions, consisting of<br />

the value of goodwill, business brands and other intangible assets recognised autonomously in<br />

the consolidated financial statements.<br />

That realignment is performed by the payment of a substitute tax of 16% and it allows the<br />

amount in question to be deducted (but not in the statutory accounts) for corporate income<br />

tax (IRES) and local production tax (IRAP) purposes at constant rates over ten years.<br />

With specific regard to the tax relief on the amounts relating to prior year extraordinary<br />

transactions, and that is those performed before the law in question entered into force, a oneoff<br />

substitute tax could be paid by 30 th November 2011, while the deduction of the<br />

amortisation (for tax purposes only) runs from 2013.<br />

As already reported in the interim financial report as at and for the period ended 30 th June<br />

2011, in view of the above, <strong>UBI</strong> <strong>Banca</strong> decided to take advantage of the option in question with<br />

regard to the following:<br />

• goodwill recognised in the consolidated financial statements as at 31 st December 2010,<br />

arising from:<br />

- the purchase price allocation performed following the merger between the former<br />

BPU <strong>Banca</strong> <strong>Group</strong> and the former <strong>Banca</strong> Lombarda e Piemontese <strong>Group</strong>, net of the<br />

€569 million already subject to tax relief in 2009 – consisting of goodwill<br />

recognised in the separate balance sheet of <strong>UBI</strong> <strong>Banca</strong> – for a total amount subject<br />

to tax relief of €2,361.7 million;<br />

- the acquisition of IW Bank, with an amount subject to tax relief of €54.6 million;<br />

• other intangible assets, recognised in the consolidated balance sheet as at 31 st<br />

December 2010, arising from the purchase price allocation following the merger<br />

between the former BPU <strong>Group</strong> and the former <strong>Banca</strong> Lombarda e Piemontese <strong>Group</strong>.<br />

In detail, these intangible assets consist of the following:<br />

- core deposits, with an amount subject to tax relief of €312 million;<br />

- assets under management, with an amount subject to tax relief of €165 million;<br />

- assets under custody, with an amount subject to tax relief of €54 million;<br />

- brands, with an amount subject to tax relief of €338 million.<br />

Reference was made with regard to the accounting treatment, as occurred in 2008, to the<br />

Italian Accountants Association (Organismo Italiano di Contabilità) document, “Application No.<br />

1 - Hypothesis for the accounting treatment for the substitute tax for tax relief on goodwill<br />

pursuant to paragraph 10, Art. 15 of Decree Law No. 185 of 29 th November 2008”. This<br />

document allows the simultaneous recognition of the substitute tax and the relative deferred<br />

tax assets in the income statement.<br />

Following the resolution, passed by the Management Board on 25 th August 2011 and<br />

confirmed by the Supervisory Board on 29 th August 2011, to take advantage of the options<br />

provided by the legislation in question, as at 30 th June 2011 the amount relating to the<br />

substitute tax (16%) was charged to the income statement and deferred tax assets based on<br />

the nominal corporate income tax rate (27.5%) were recognised 2 .<br />

With regard to deferred local production tax (IRAP) assets, the decision to take advantage of<br />

the tax relief resulted in a decrease in the tax base of <strong>UBI</strong> <strong>Banca</strong> of €328,526 thousand, with a<br />

2 In this regard, in compliance with IAS 12 tax assets are recognised on the assumption that it is probable that<br />

sufficient taxable profit will be available against which the deductible temporary difference can be utilised.<br />

247

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