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Prospectus - Notowania

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esolution following the one pertaining to the profit of the year ongoing as at<br />

December 31, 2007, the profits produced by the company until that date are<br />

considered distributed by priority.<br />

Partnerships, joint-stock companies and business entities<br />

The dividends collected by general partnerships, limited partnerships and<br />

equivalents (excluding non-business associations) as per Article 5, Italian<br />

Presidential Decree 917/1986, and by persons subject to the income tax on<br />

companies (“IRES”) as per Article 73, first Paragraph, Letters a) and b), Italian<br />

Presidential Decree 917/1986, i.e. by joint-stock companies, limited partnerships,<br />

limited liability companies, public and private entities whose exclusive or main<br />

purpose is to perform commercial activities, fiscally residing in Italy, are not<br />

subject to withholding tax or substitute tax.<br />

In particular, the dividends collected by:<br />

− partnerships (e.g., general partnerships and limited partnerships), partially<br />

contribute to the formation of the total taxable income of the percipient<br />

shareholder for 49.72% of the related amount, with reference to the dividends<br />

distributed on profits produced starting from the year following the one<br />

ongoing as at December 31, 2007;<br />

− persons subject to IRES (e.g., joint-stock companies and limited partnerships<br />

in which the interests of limited partners are represented by shares), contribute<br />

to firm the total taxable income of the percipient for only 5% of their amount,<br />

subject to ordinary rate, currently 27.5%. The dividends collected by<br />

companies that prepare the financial statements in accordance with<br />

International Accounting Standards, in relation to shares held for trading,<br />

contribute to the formation of taxable income for their entire amount.<br />

Non Commercial Entities<br />

The dividends collected by the entities as per Article 73, First Paragraph,<br />

Letter c) Presidential Decree 917/1986, i.e. by public and private entities,<br />

other than companies, whose exclusive or main purpose is not to perform<br />

commercial activities, are not subject to any withholding tax or substitute tax<br />

and they contribute to the formation of the IRES taxable income of said<br />

entities for 5% of their amount.<br />

Exempt Persons<br />

The dividends collected by IRES exempt persons are subject to a withholding<br />

tax with the rate of 27%. However, on the dividends distributed on profits<br />

deriving from shares inserted in the centralised deposit system managed by<br />

Monte Titoli, such as the Shares, a tax substituting income tax, drawn with the<br />

same rate of 27%, is applied in lieu of the aforesaid withholding tax.<br />

Real Estate Mutual Funds<br />

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