Common use of ADDITIONAL INFORMATION Clause in Contracts

ADDITIONAL INFORMATION. The statements herein regarding taxation are based on the laws in force in Italy as at the date of this Final Terms and are subject to any changes in law occurring after such date, which changes could be made on a retroactive basis. The following summary does not purport to be a comprehensive description of all the tax considerations which may be relevant to a decision to subscribe for, purchase, own or dispose of the Securities and does not purport to deal with the tax consequences applicable to all categories of investors, some of which (such as dealers in securities or commodities) may be subject to special rules. Prospective investors are advised to consult their own tax advisers concerning the overall tax consequences of their interest in the Securities. In accordance with the Italian tax regime currently in force, where the Italian resident Holder is (i) an individual not engaged in an entrepreneurial activity to which the Securities are connected, (ii) a non-commercial partnership with the exception of general partnership, limited partnership and similar entities, (iii) a non-commercial private or public institution, or (iv) an investor exempt from Italian corporate interest, premium and other income accrued during the relevant holding period are subject to a 20 per cent substitute tax (imposta sostitutiva) (20 per cent for interest, premium and other income accrued as of or following 1 January 2012) pursuant to the legislative decree 1 April 1996 n. 239. Where an Italian resident Holder is a company or similar commercial entity, or the Italian permanent establishment of a foreign commercial entity to which the Securities are effectively connected, interest, premium and other income arising from the Securities will not be subject to imposta sostitutiva, but must be included in the relevant Holder's income tax return and are therefore subject to Italian corporate tax. No Italian imposta sostitutiva is applied on payments to a non-Italian resident Holder of interest or premium relating to the Securities provided that, if the Securities are held in Italy, the non Italian resident Holder declares itself to be a non-Italian resident according to Italian tax regulations. Any capital gains realised by Holders included in the above (i) to (iv) from the sale of the Securities are subject to a substitutive tax (imposta sostitutiva) applied at a rate of 20 per cent. pursuant to the legislative decree 21 November 1997 n. 461 as amended from time to time.

ADDITIONAL INFORMATION. The statements herein regarding taxation are based on the laws in force in Italy as at the date of this Final Terms and are subject to any changes in law occurring after such date, which changes could be made on a retroactive basis. The following summary does not purport to be a comprehensive description of all the tax considerations which may be relevant to a decision to subscribe for, purchase, own or dispose of the Securities Notes and does not purport to deal with the tax consequences applicable to all categories of investors, some of which (such as dealers in securities or commodities) may be subject to special rules. Prospective investors are advised to consult their own tax advisers concerning the overall tax consequences of their interest in the SecuritiesNotes. In accordance with the Italian tax regime currently in force, where the Italian resident Holder Noteholder is (i) an individual not engaged in an entrepreneurial activity to which the Securities Notes are connected, (ii) a non-commercial partnership with the exception of general partnership, limited partnership and similar entities, (iii) a non-non- commercial private or public institution, or (iv) an investor exempt from Italian corporate interest, premium and other income accrued during the relevant holding period are subject to a 20 12.5 per cent substitute tax (imposta sostitutiva) (20 per cent for interest, premium and other income accrued as of or following 1 January 2012) pursuant to the legislative decree 1 April 1996 n. 239. Where an Italian resident Holder Noteholder is a company or similar commercial entity, or the Italian permanent establishment of a foreign commercial entity to which the Securities Notes are effectively connected, interest, premium and other income arising from the Securities Notes will not be subject to imposta sostitutiva, but must be included in the relevant HolderNoteholder's income tax return and are therefore subject to Italian corporate tax. No Italian imposta sostitutiva is applied on payments to a non-Italian resident Holder Noteholder of interest or premium relating to the Securities Notes provided that, if the Securities Notes are held in Italy, the non non-Italian resident Holder Noteholder declares itself to be a non-Italian resident according to Italian tax regulations. In the event that Notes are redeemed, in full or in part, prior to 18 months from their issue date, or, at certain conditions, if repurchased by the Issuer within this period, Italian resident Noteholders will be required to pay, by way of a withholding to be applied by the Italian intermediary responsible for payment of interest or the redemption of the Notes, an amount equal to 20 per cent. of the interest and other amounts accrued up to the time of the early redemption. The 20 per cent. surcharge applicable in the case previously described will not longer apply as of 1 January 2012. Any capital gains realised realized by Holders Noteholders included in the above (i) to (iv) from the sale of the Securities Notes are subject to a substitutive tax (imposta sostitutiva) applied at a rate of 20 12.50 per cent. (20 per cent for capital gains realized as of or following 1 January 2012) pursuant to the legislative decree 21 November 1997 n. 461 as amended from time to time.

ADDITIONAL INFORMATION. The statements herein regarding taxation are based on the laws in force in Italy as at the date of this Final Terms and are subject to any changes in law occurring after such date, which changes could be made on a retroactive basis. The following summary does not purport to be a comprehensive description of all the tax considerations which may be relevant to a decision to subscribe for, purchase, own or dispose of the Securities and does not purport to deal with the tax consequences applicable to all categories of investors, some of which (such as dealers in securities or commodities) may be subject to special rules. Prospective investors are advised to consult their own tax advisers concerning the overall tax consequences of their interest in the Securities. In accordance with With regard to certain innovative or structured financial instruments there is currently neither case law nor comments of the Italian tax regime currently in forceauthorities as to the tax treatment of such financial instruments. Accordingly, it cannot be excluded that the Italian tax authorities and courts or Italian intermediaries may adopt a view different from that outlined below. Pursuant to Article 67 of Presidential Decree No. 917 of 22 December 1986 and Legislative Decree No. 461 of 21 November 1997, as subsequently amended, where the Italian resident Holder is (i) an individual not engaged in an entrepreneurial activity to which the Securities are connected, (ii) a non-non commercial partnership with the exception of general partnership, limited partnership and similar entities, (iii) a non-commercial private or public institution, or (iv) an investor exempt from Italian corporate interestincome taxation, premium and other income accrued during capital gains realised under the relevant holding period sale or the exercise of the Securities are subject to a 20 per cent cent. substitute tax. Particular provisions apply to Securities held or managed by a qualified intermediary; the recipient may opt for two different tax regime: (1) under the "risparmio amministrato" regime, Italian resident individuals holding the Securities not in connection with an entrepreneurial activity may elect to pay the imposta sostitutivasostitutiva separately on each capital gains realised on the Securities; (2) (under the "risparmio gestito" regime any capital gains realised or accrued by the Italian resident individuals holding the Securities not in connection with an entrepreneurial activity who have entrusted the management of their financial assets, including the Securities, will be included in the computation of the annual increase in value of the managed assets accrued, even if not realised, at year end, subject to a 20 per cent cent. substitute tax, to be paid by the managing authorised intermediary. Under some conditions and limitations, Holders may set off capital losses (decrease in value for interest, premium and other income the risparmio gestito regime) with capital gains (increase in value for the risparmio gestito regime). Capital losses realised (decrease in value accrued as of or following for the risparmio gestito regime) before 1 January 20122012 may be carried forward to be offset against subsequent capital gains (increase in value accrued for the risparmio gestito regime) pursuant to of the legislative decree 1 April 1996 n. 239same nature for an overall sum of 62.5 per cent. of the relevant amount. Where an Italian resident Holder is a company or similar commercial entity, or the Italian permanent establishment of a foreign commercial entity to which the Securities are effectively connected, interest, premium and other income capital gains arising from the Securities will not be subject to imposta sostitutiva, but must be included in the relevant Holder's income tax return and are therefore subject to Italian corporate tax. No Italian imposta sostitutiva is applied on payments to a non-Italian resident Holder of interest or premium relating to the Securities provided that, if the Securities are held in Italy, the non Italian resident Holder declares itself to be a non-Italian resident according to Italian tax regulations. Any capital gains realised by Holders included in the above (i) to (iv) from the sale of the Securities are subject to a substitutive tax (imposta sostitutiva) applied at a rate of 20 per cent. pursuant to the legislative decree 21 November 1997 n. 461 as amended from time to time.