Prospectus - Notowania

partnerships in which the interests of limited partners are represented by
shares, limited liability companies, public and private entities whose sole or
main purpose is to exercise commercial activities contribute to form their
total taxable income for their entire amount according to the ordinary tax
treatment, i.e. if the transferred Shares were recorded as financial fixed assets
in the last three financial statements, the disposing person may opt to let any
capital gain achieved in the tax period of interest and in the subsequent ones,
but not beyond the fourth period, contribute to taxation. Realised capital
losses are generally deductible; however, they are not relevant until reaching
the non taxable amount of the dividends, or of their advances, collected in the
thirty-six months preceding the realisation, with reference to the Shares
acquired in the thirty-six months preceding said realisation, unless the
transferor prepares the financial statements in accordance with the
International Accounting Standards.
The capital gains realised as a result of the disposal for good, valuable and
fungible consideration of shares of companies residing in Italy traded in a
regulated market, such as the Shares, do not contribute to the formation of the
taxable income for IRES purposes for 95%, and are therefore subject to
taxation for IRES purposes solely for the residual 5%, provided that:
(a) the share was held uninterruptedly by the transferor from the first
day of the twelfth month preceding the month of the transfer,
considering transferred first the shares acquired most recently;
(b) the share had been classified in the category of financial fixed
assets in the first financial statements closed during the period of
possession
The related capital losses, instead, are totally non-deductible if the shares
were not held uninterruptedly from the first day of the twelfth month
preceding the month of the transfer. In relation to the deductible capital
losses, it should be stressed, however, that if the amount of the aforesaid
capital losses exceeds €50,000, even as a result of multiple transactions, the
taxpayer shall notify the data and information about the transaction to the
Italian Inland Revenue. The detail of the information that shall be provided in
the notice, in addition to the terms and procedures of said notice, are set by
the Italian Inland Revenue instruction of March 29, 2007. In case of omitted,
incomplete or unfaithful notice, the realised capital loss will not be deductible
for tax purposes.
For certain types of companies, such as banks and insurance companies, and
under certain conditions, the capital gains realised by the aforesaid persons by
transfer of shares contribute to form also the related net value of production,
subject to regional tax on production (“IRAP”), generally drawn with a rate
of 3.9%.
Non Commercial Entities
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