Prospectus - Notowania

shareholders, and the companies and entities indicated in the previous
Paragraph, can ask for reimbursement, up to 4/9 of the tax withheld in Italy,
of the tax they demonstrate they have definitively paid abroad on the same
profits, upon showing the related certification of the tax office of the foreign
State to the cognisant Italian tax authorities.
Alternatively to the aforesaid reimbursement, a reduction of the rate may be
applied by virtue of any relevant international conventions against double
taxation. Such international conventions generally recognise the right of the
non resident shareholder to request reimbursement of the excess amount of
the tax withheld by virtue of internal Italian rules with respect to the tax
applicable according to the convention. However, with reference to the shares
centralised with the Monte Titoli system, such as the Shares, the
intermediaries with whom the securities are deposited or their tax
representative, in case of non resident intermediaries, apply the conventional
rate directly if they acquire prior to the payment of the dividend and according
to the procedures they indicate to the shareholders:
− a statement of the non resident person who is the actual beneficiary of the
profits, providing the identifying data of that person, the existence of all
conditions to which the application of the conventional treatment is
subordinated and any elements necessary to determine the measure of the
rate applicable in accordance with the convention;
− a certification of the cognisant tax authority of the State where the actual
beneficiary of the profits resides, proving residence in that State in
accordance with the convention; said certification is effective until March
31 of the year after the year of its presentation.
Distribution of Reserves
Specific instructions regulate the taxation of the distribution of some reserves,
including reserves or funds constituted with issue premiums, with balance
interest paid by the underwriters, with non returnable or capital account
shareholders’ payments and with tax exempt currency revaluation balances. In
certain circumstances, this distribution can originate taxable income for the
percipient depending on the existence of operating profits and of the reserves
recorded in the financial statements of the company on the date of the
distribution and on the nature of the distributed reserves. The enforcement of
these instructions may impact on the measurement of the fiscally recognised
cost of the Shares or on the qualification of the collected income and of the
related tax treatment applicable to it. Non resident shareholders may be
subject to taxation in Italy as a result of the distribution of said reserves.
We recommend consulting your tax advisor in case of distribution of such
reserves.
Capital Gains Deriving from the Transfer of Shares
Resident Persons
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