UBI Banca Group

presented an application for tax assessment by consent after an application for internal review
was not accepted.
TAX ASSESSMENT REPORTS
UBI Leasing (2006-2009) increased taxation of €0.41 million
These were allegations relating to the application of a subsidised VAT rate on marine lease
transactions and undue deduction of VAT on invoices for transactions considered non existent by
the tax authorities. For similar allegations relating to prior years the tax authorities have already
issued notices of tax assessment reported above.
Silf (2007) increased taxation of €0.4 million
Allegations concerning irregularities in the deductibility of some expenses during the year (in
particular, those related to commission expenses paid to financial advisors) and of loan losses as
well as the quantification of the recognition of impairment losses on loans for the year.
Observations were presented against the demands in the tax assessment report as permitted by
the taxpayers’ statute (Law No. 212/2000).
UBI Leasing (2007-2010) increased taxation of €7.2 million
These were allegations concerning property leasing transactions involving the construction of the
property, considered by the inspectors as irregular sale and lease back transactions. Observations
were presented against the tax assessment report as permitted by the taxpayers’ statute (Law No.
212/2000).
Banca Regionale Europea (2008) increased taxation of €0.9 million
These were allegations concerning the tax deduction of the loss resulting from the disposal
without recourse of the loans to a customer in difficulty performed by the bank in 2008. More
specifically, the Piedmont Regional Department of the tax authorities alleged the absence of the
assumptions of certainty and finality of the disposal because of the existence of guarantees
granted to the creditors recognised by the purchaser.
OTHER TAX LITIGATION
Further tax liability litigation exists, relating mainly to years prior to 31 st December 2006 which
regard the matters listed below.
UBI Banca (1983 and 1984 former Banca Popolare Bergamo Scrl) increased taxation of €1.93
million
These consist of cases pending before the Central Tax Commission, concerning appeals against
notices of assessment, mainly regarding the recovery of taxes on expenses deducted fully by the
bank and not proportionately as held by the tax authorities.
Banca Regionale Europea (2003) fines of €1.2 million
This is litigation relating to the procedures followed by the bank to adjust its income tax return
originally filed for 2003. The case is currently pending before the Supreme Court of Cassation
brought by the tax authorities against the decision in favour of the bank by the court of first
instance.
Banco di Brescia (2003 and 2004) increased taxation of €0.40 million
This consists of litigation concerning tax collection demands arising from the alleged erroneous
application for the years 2003 and 2004, of the rate for IRAP on the value of production relating to
the Veneto Region. The appeals lodged by Banco di Brescia were recently accepted by the relative
regional tax commission.
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