Prospectus - Notowania

Non Qualifying Holdings contribute to form the increase in managed
assets accrued in the related tax period, subject to the substitute tax of
12.5%. The negative result of operations achieved in a tax period may be
computed to reduce the positive result of operations of the four
subsequent tax periods for the amount that fits in each of them.
Exercising the option for the second or third treatment causes the
investor not to be obliged to report the capital gains realised in his
income tax return.
(b) Disposal of Qualifying Holdings
The capital gains, net of the related capital losses, deriving from Disposals of
Qualifying Holdings achieved by natural persons outside the operation of
commercial enterprises contributed only partially to the formation of taxable
income for IRPEF purposes. Implementing the 2008 Budget Law, the
Ministry of the Economy and Finance, with ministerial decree of April 2,
2008, raised the taxable part of said capital gains from 40% to 49.72% of the
related amount, with reference to the capital gains realised starting from
January 1, 2009. The previous rate of 40% for the contribution to the
formation of taxable income remains applicable also for the capital gains
related to realisations completed before January 1, 2009 but whose payments
were collected in full or in part starting from the same date. The taxation of
capital gains realised by Disposals of Qualifying Holdings takes place
exclusively upon the annual tax return.
Capital losses are deducted from the taxable income for the same amount
and, if they exceed the capital gains realised in a given tax period, they can be
brought forward as deductions, to exhaustion, from the capital gains realised
in subsequent tax periods, but not beyond the fourth such period.
Natural persons exercising enterprise activities and Partnership
The capital gains realised by fiscally resident natural persons in relation to
Shares related to the enterprise, as well as by general partnerships, limited
partnerships and equivalent as per Article 5, Presidential Decree no.
917/1986, excluding non-business associations, by disposal of the Shares for
good, valuable and fungible considerations, contribute for the entire amount
to form the taxable enterprise income, subject to taxation in Italy according to
the ordinary treatment. However, if the de facto and de jure conditions
indicated herein are met, the capital gains contribute to the formation of the
taxable enterprise income for 49.72% of the related amount, with reference to
the capital gains realised starting from January 1, 2009 (see the preceding
Paragraph on the taxation of capital gains realised by resident natural persons
by Disposal of Qualifying Holdings).
Corporations and business entities
The capital gains deriving from disposals for good, valuable and fungible
consideration of Shares, completed by joint-stock companies and limited
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