Prospectus - Notowania

Natural persons
Capital gains, other than those achieved in the operation of commercial
enterprises, realised by natural persons fiscally residing in Italy by disposal
for good, valuable and fungible consideration of the Shares, as well as of
securities or rights through which the Shares can be acquired, are subject to a
different tax treatment according to whether it is a Disposal of Qualifying
Holdings or a Disposal of Non Qualifying Holdings.
(a) Disposal of Non Qualifying Holdings
The capital gains, net of the associated capital losses, deriving from Disposals
of Non Qualifying Holdings are subject to the substitute tax on share capital
gains, drawn with the rate of 12.5%, based on one of the following
treatments:
• so-called “return treatment”: this is the treatment ordinarily applicable,
unless the taxpayer opts for one of the other two treatments described
below; the taxpayer shall indicated in the income tax return the capital
gains realised during the tax period and pay the substitute tax within the
terms and in the manners prescribed for payment of income tax due in
relation to the same period. If the total amount of the capital losses is
greater than that of the capital gains, the excess can be deducted until the
value is equal to that of the capital gains realised in subsequent tax
period, but not beyond the fourth period;
• so-called “administered savings treatment”: it may find application
provided that the Shares are entrusted in custody or administration to an
authorised intermediary and the taxpayer communicates in writing that
he wants to opt for this treatment; the substitute tax is paid by the
authorised intermediary on the capital gains realised as a result of each
disposal of the Shares by withholding a tax on the amounts to be paid to
the shareholder. Any loss deriving from the disposal of the Shares may
be compensated with any capital gains realised subsequently, within the
same relationship, in the same tax period or in the four subsequent ones;
• so-called “managed savings treatment”: a prerequisite for the selection
of this treatment is to appoint an authorised intermediary to manage
assets. If this treatment is applied, at the end of each tax period the
intermediary applies a substitute tax of 12.5% on the increase in the
managed assets accrued within the tax period, even if it was not
collected, net of income subject to withholding tax, of income that is
exempt or otherwise not subject to taxation, of the income that
contributes to form the taxpayer’s total income, of the revenues deriving
from shares of undertakings for collective investment in transferable
securities subject to substitute tax as per Article 8, Italian Legislative
Decree no. 461 of November 21, 1997 and from Mutual funds investing
in securities as per Italian Law no. 86 of January 25, 1994. In the
managed savings treatment, the capital gains realised by the Disposal of
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