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Prospectus - Notowania

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Capital gains realised by resident non commercial entities are subject to<br />

taxation with the same rules prescribed for capital gains realised by natural<br />

persons on shares held under other than enterprise treatment.<br />

Pension Funds and UCITS<br />

The capital gains realised by pension funds fiscally residing in Italy as well as<br />

by UCITS are subject to the same treatment described in the Paragraph on<br />

taxation of dividends collected by such persons.<br />

Real Estate Mutual Funds<br />

Capital gains realised by real estate mutual funds instituted in accordance<br />

with Article 37 of the TUF and with Article 14-bis of Italian Law no. 86 of<br />

January 25, 1994, are subject to the same treatment described in the<br />

Paragraph on the taxation of dividends collected by such persons.<br />

Non Resident Persons<br />

Capital gains realised by persons not residing fiscally in Italy, lacking a stable<br />

organisation in Italy to which the shares are actually connected, deriving<br />

from:<br />

− Disposals of Non Qualifying Holdings in companies whose shares are<br />

traded in regulated market, like UniCredit, are not subject to taxation in<br />

Italy, even if held there. To benefit from said exemption, shareholders not<br />

residing fiscally in Italy may have to produce a self-certification declaring<br />

that they do not reside fiscally in Italy;<br />

− Disposals of Qualifying Holdings contribute to the formation of the<br />

transferor’s total income for 49.72% of the related amount, with reference<br />

to the capital gains realised starting from January 1, 2009 (see the<br />

preceding Paragraph on the taxation of capital gains realised by resident<br />

natural persons by Disposal of Qualifying Holdings).<br />

Any exemption in Italy which may be provided by international conventions<br />

against double taxation, when applicable, remains valid in any case.<br />

With respect to non resident persons who hold the share through a stable<br />

organisation in Italy, such amounts contribute to the formation of the income<br />

of the stable organisation according to the tax treatment prescribed for capital<br />

gains realised by corporations that reside fiscally in Italy.<br />

Tax on Stock Exchange Contracts<br />

Law Decree no. 248 of 31 December 2007, converted by Italian Law no. 31 of<br />

February 28, 2008, repealed the tax on stock exchange contracts, regulated by<br />

Royal Decree no. 3278 of December 30, 1923, as amended by Article 1 of<br />

Italian Legislative Decree no. 435 of November 21, 1997.<br />

Inheritance Tax and Donation Tax<br />

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