Prospectus - Notowania

In order to eliminate the double taxation of such income, the Double Taxation Treaty provides
for tax credit method. Where the Polish corporation derives income such as dividend, which
may be taxed in Italy, the latter is allowed to deduct from the domestic tax on its income of the
amount equal to the tax paid (withheld) in Italy. Such deduction shall not however exceed that
part of the tax as computed before the deduction is given, which is appropriate to such income
derived in Italy.
Furthermore, income (revenue) on dividends and other income from participation in profits
earned by corporate entities may also be exempt from income tax in the case of shareholders
that are corporate entities and hold larger blocks of shares on the terms set forth below in
“Exemption of Dividends and Other Income from Shares Held by Polish and Foreign Corporate
Entities from Income Tax.”
Exemption of Dividends and Other Income from Shares Held by Polish and Foreign
Corporate Entities from Income Tax
Pursuant to the CIT Law, an income tax exemption applies to dividends and other income
(revenue) actually earned on the shares by a company whose entire income is taxed in Poland
or in another European Union member state or European Economic Area member state
(regardless of where the income is earned) if all of the following conditions are met:
(1) the company that earns the income holds directly not less than 10% of all the shares;
(2) the company that earns the income has continuously held the number of shares specified in
item (1) above for two years. It should be noted that the exemption also applies if the required
two-year period expires after the income earning date. Should the above condition not be met,
the company benefiting from the exemption will be required to pay the tax otherwise due by
the 20th day of the month following the month in which such company lost the right to the
exemption, including any accrued default interest, and
(3) the place of the registered office of the company earning the income is documented for tax
purposes by a certificate of tax residency issued by the relevant foreign tax authority.
Assuming that the foregoing conditions are met, the exemption will also apply if the recipient
of dividends is a foreign permanent establishment (within the meaning of the CIT Law) of a
company whose entire income (regardless of the place in which it is earned) is taxed in Poland
or in another European Union member state or European Economic Area member state. The
existence of a foreign permanent establishment should be evidenced by the company that
benefits from the exemption by a certificate issued by the applicable tax authority of the
country, in which the company’s registered office and/or place of management is located, or by
the applicable tax authority of the country, in which the permanent establishment is located.
Taxation of income from trading in shares
Income of Polish Individuals Trading in Shares
As a rule, the PIT Law provides for the flat 19% tax rate to income from the disposal of
securities against consideration. However, this tax rate shall not apply if UniCredit shares are
disposed of by an individual within the framework of the individual taxpayer’s business
activity (in the latter case they are taxed with other business income on terms applicable for
taxation of such business income chosen by such individual, i.e. either at 19% or with
progressive rates).
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