Prospectus - Notowania

4.11.3 Poland
The following summary describes the material Polish tax consequences related to the
acquisition, holding and trading in UniCredit Shares and Rights as of the date hereof. This
summary is of general nature and is not intended to constitute a comprehensive or complete
analysis of all Polish tax considerations that may be relevant to shareholders being tax
residents in Poland.
The tax information presented in this Offering Circular does not constitute individual tax
advice. In particular, it should not constitute the sole grounds for assessing the domestic tax
consequences of making any investment decisions. In order to obtain more detailed
information, investors are strongly recommended to consult their own tax and legal advisers in
order to confirm all applicable tax consequences related to the acquisition, holding and trading
in UniCredit Shares and/or Rights. The information presented below has been prepared based
on provisions of the Polish law in force, effective as of the date of this Offering Circular.
Please note that the provisions of law described herein are subject to changes, which may
directly or indirectly modify the description below.
Taxation of Income Related to the Holding of Shares
Income from UniCredit shares Held by Individuals Subject to Unlimited Tax Liability
in Poland
Pursuant to the Personal Income Tax (“PIT”) Law, dated July 26, 1991 (unified text published
in Journal of Laws of 2000, no. 14 item 176 as amended), an individual is subject to unlimited
tax liability in Poland (i.e., is taxable on his/her worldwide income) provided that such
individual is domiciled in Poland, i.e. she/he has the center of his/her personal and/or business
interests in Poland (center of vital interests) and/or the stay of such individual in Poland in the
tax year exceeds 183 days. Dividends and other income (revenue) actually earned on UniCredit
shares held by these individuals are taxed at a rate of 19%. The tax is applied without any
decrease for tax-deductible expenses.
The above income is not subject to accumulation with other income earned during a tax year,
taxable pursuant to general PIT rules, i.e. at the progressive tax rates set forth in the PIT Law
(i.e. as of January 1, 2009, 18% and 32% depending on thresholds).
As a rule, the tax on income applied pursuant to foregoing rules is collected by a remitter, i.e.
an entity that disburses or makes dividends and other income (revenues) actually earned from
shares, which is taxed at the flat 19% rate available to the taxpayer. The remitter is required to
send an annual tax return to the relevant tax office by the end of January in the year following
the tax year. The remitter is not required to send individual notices to Polish taxpayers
informing them of the amount of income (revenues). Taxpayers are not required to disclose the
flat tax withheld by the remitter in their annual tax return.
With respect to the UniCredit shares, however, any distributions would be made by a foreign
entity which does not have its registered office in Poland. Therefore, Polish regulations cannot
impose any obligation on UniCredit to withhold Polish tax as a tax remitter. Therefore, unless
the Polish tax authorities would be of the view that the income tax should be withheld by any
Polish resident acting as an intermediary for the purpose of dividend distributions (if any),
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