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Prospectus - Notowania

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action admissable, the sum requested could increase in an exponential way in relation to the<br />

number of adesions of current account holders of UniCredit Banca di Roma who considered<br />

themselves injured by the bank’s behaviour.<br />

According to a statement issued by CODACONS, the sum which could be requested from<br />

UniCredit by the current account holders within the context of this action could be €1 billion.<br />

Based on the petition served, the Company – which considers that it acted in compliance with<br />

regulations – does not possess the necessary elements to assess the quantification of the<br />

amount mentioned in the statement.<br />

20.9. Tax proceedings<br />

Investigations regarding cross-border transactions<br />

Based on some press reports, the Milan Public Prosecutor’s Office, with the cooperation of the<br />

Finance Police, began conducting an investigation in May 2009 regarding the possible tax and<br />

legal implications of certain financial transactions executed by the Italian companies of<br />

UniCredit Group. As at the Date of the <strong>Prospectus</strong>, the investigation may be against unknown<br />

parties, as far as the Issuer is aware.<br />

The aforementioned financial transactions are investments made as part of the Group’s liquidity<br />

management, carried out primarily through repurchase agreements with other major<br />

international banks.<br />

Although the Issuer maintains that the transactions were conducted properly, said investigations<br />

may turn into complaints by the Authorities and the proceedings may have detrimental effects<br />

for the UniCredit Group companies involved.<br />

Dispute with the Italian Tax Authority<br />

As at the Date of the <strong>Prospectus</strong>, three tax cases are pending with the Palermo Regional Tax<br />

Commission regarding: (i) objection by Palermo Inland Revenue to a credit for an amount of<br />

€25.6 million for income tax of legal persons (IRPEG) resulting from the 1984 annual revenue<br />

declaration of Cassa Centrale di Risparmio V.E. per le Province Siciliane (now Banco di<br />

Sicilia); (ii) objection to a credit in the amount of €21.1 million for income tax of legal persons<br />

(IRPEG) resulting from the 1984 annual revenue declaration of Banco di Sicilia; and (iii)<br />

objection to a credit in the amount of €24.3 million for income tax of legal persons (IRPEG)<br />

resulting from the 1985 annual revenue declaration of Banco di Sicilia. The total value of the<br />

challenges, including interest accrued and recognised, is €165 million.<br />

The Palermo Regional Tax Commission rejected the claims filed by Banco di Sicilia in its<br />

decision of June 12, 2007. Banco di Sicilia has filed an appeal. Two of the hearings are set for<br />

November 2009 while a third hearing will take place on January 22, 2010.<br />

The Company does not have knowledge of the filing date of the rulings by the Provincial Tax<br />

Commission of Palermo and it is, therefore, possible that it may occur over the course of the<br />

Offer.<br />

No provisions were made in relation to these proceedings.<br />

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