Prospectus - Notowania

In accordance with Italian Law Decree no. 351 of September 25, 2001,
converted with amendments into Italian Law no. 410 of November 23, 2001,
and as a result of the amendments made with Article 41-bis of Italian Law
Decree no. 269 of September 30, 2003, converted with amendments into
Italian Law no. 326 of November 24, 2003, the dividends collected by real
estate mutual funds instituted in accordance with Article 37 of the TUF, or of
Article 14-bis of Italian Law no. 86 of January 25, 1994, as well as by the real
estate investment funds instituted before September 26, 2001, are not subject
to any withholding tax. These funds, in addition to not being subject to
income taxes and to the regional tax on production, are not subject to any
substitute tax on the net asset value of the fund. The income deriving from
shares in these funds are generally subject to a withholding tax of 20%.
Pension Funds and UCITS
Dividends collected by pension funds as per Italian Legislative Decree no.
252 of December 5, 2005 and dividends collected by Italian Undertakings for
Collective Investment in Transferable Securities (“UCITS”), subject to the
treatment as per Article 8, Paragraphs 1 through 4, Legislative Decree no. 461
of November 21, 1997, are not subject to any withholding tax or substitute tax
and contribute to the formation of the related annual operating income
accrued by them, subject to a substitute tax drawn with the rate of 11% for
pension funds and 12.5% for UCITS.
Dividends Collected by Non-Resident Persons
Dividends collected by persons not residing in Italy and lacking a stable
organisation in the territory of the State where the shares are actually
connected are subject to a withholding tax of 27%. With regard to the shares
centralised with the Monte Titoli system, such as the Shares, instead of the
aforesaid withholding tax, a substitute tax is applied with the same rate of
27% (on said substitute tax, please see the previous paragraph on the taxation
of the dividends collected by resident natural persons). If, instead, the non
resident person has a stable organisation in Italy and the share with reference
to which the dividends are paid is actually connected to it, the paying person
does not have to apply any withholding tax and the dividend contribute to the
determination of the business income of the stable organisation subject to
taxation in Italy with a rate of 5% of their amount, or for the entire amount if
they relate to securities held for trading by persons who apply the
International Accounting Standards.
The withholding tax is reduced to 1.375% on dividends distributed on profits
produced starting from the financial year following the one ongoing as at
December 31, 2007 to companies and entities (i) fiscally residing in a member
State of the European Union, or in a State adhering to the agreement on the
European economic space included in the list to be prepared with decree of
the Ministry of the Economy and Finance in accordance with Article 168-bis,
Italian Presidential Decree 917/1986, and (ii) subject to income tax therein.
Shareholders not residing in Italy for fiscal purposes, other than savings
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