Prospectus - Notowania

With regard to individuals, income (revenues) on disposal of the UniCredit shares for
consideration is defined as the selling price of the UniCredit shares. However, it should be
noted that if the price specified in the share sales agreement for consideration is not determined
at arm’s length, i.e. differs materially, without a legitimate reason, from the market value of the
UniCredit shares, it may be challenged by the tax authorities. With respect to disposal against
consideration, the expenditures incurred to acquire the UniCredit shares constitute taxdeductible
expenses of such disposal, reducing the taxable base.
Pursuant to the PIT Law, if it is not possible to identify the UniCredit shares being sold, it is
assumed that they are the earliest acquired UniCredit shares (the FIFO rule). This principle is
applied separately to each securities account where the UniCredit shares are held.
After the end of a tax year, taxpayers are obliged to disclose, in a separate tax return, income
earned during the given year from the disposal of shares for consideration (the revenue on the
sale of UniCredit shares is the revenue due, even if not actually obtained, which affects the cutoff
date for income classification), and calculate the income tax due. This tax return must be
filed by April 30 of the year following the given tax year (this also being the deadline for
paying the tax so calculated).
With respect to income on disposal of UniCredit shares for consideration, there is no obligation
for the tax remitter to collect and remit tax advances during the tax year.
Pursuant to the PIT Law, losses sustained during a tax year on account of the disposal of shares
for consideration can be deducted from the income derived from that source (such source of
income includes, in particular, income from the transfer of shares and other securities for
consideration) over the five subsequent tax years, provided that the amount of the deduction
does not exceed 50% of the amount of the loss in any single year within the five-year period.
Income of Polish Corporate Entities Trading in Shares
Income on the disposal of shares for consideration earned by corporate entities (including those
in course of formation, i.e. not vested with legal personality yet), as well as other
unincorporated entities (except civil law partnerships, general partnerships, limited
partnerships, limited liability partnerships and partnerships limited by shares) with their
registered office or place of management in Poland subject to taxation in accordance with the
general rules under the CIT Law. They are taxed at the rate of 19%, together with other income
earned during the given fiscal year.
With respect to corporate entities, income (revenues) on disposal of the UniCredit shares for
consideration is defined as the selling price of the UniCredit shares. However, it should be
noted that if the price specified in the share sales agreement for consideration is not determined
at arm’s length, i.e. differs materially, without a legitimate reason, from the market value of the
UniCredit shares, it may be challenged by the tax authorities. With respect to disposal against
consideration, the expenditures incurred to acquire the UniCredit shares constitute taxdeductible
expenses of such disposal, reducing the taxable base.
Income of Foreign Persons Trading in Shares in Poland
Foreign persons (i.e. entities whose registered office and/or place of management is not in
Poland and individuals who are not domiciled in Poland) holding shares in a Polish company
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