Taxation in Italy. The information set out below is a summary, pursuant to Italian tax legislation and market practice, of the tax regime for the purchase, holding, sale and exercise of Certificates on the part of individual investors resident in Italy, not engaged in entrepreneurial activity. The following is not intended to be a complete analysis of all tax consequences of the purchase, holding, sale and exercise of Certificates. The following is based on the tax legislation in force as of the date of this Base Prospectus, it being understood that such legislation is subject to possible changes which could have retrospective effects, and represents only an introduction to the subject. Investors are advised to obtain professional advice with regard to the tax regime for the purchase, holding, sale and exercise of the Certificates. Under the joint provisions of article 67 of the Consolidated Act on Income Taxes (Testo Unico delle Imposte sui Redditi) passed by Decree of the President of the Republic of 22 December 1986, no. 917, as modified by Legislative Decree of 12 December 2003, no. 344, Legislative Decree of 18 November 2005, no. 247, and article 5 of Legislative Decree of 21 November 1997, n. 461, and further amendments thereof, proceeds and capital gains, not obtained within the exercise of entrepreneurial activities, realized by persons resident in Italy and individuals equivalent to residents as defined in the Decree no. 461/1997, as amended, arising out of both the exercise and the sale for money consideration of Certificates are subject to substitutive tax of 12.5 per cent. Charges and capital losses arising out of the exercise and sale of Certificates are deductible in accordance with the modalities indicated below; premiums paid on Certificates contribute to create the income of the financial year in which the Certificates are exercised or alienated. The tax-payer may opt among three different alternative taxation regimes: the taxation based on the annual tax return, which constitutes the so called "base regime" applicable unless the exercise of an option by the tax payer; the "risparmio amministrato" regime and the "risparmio gestito" regime:
Taxation in Italy. The information set out below is a summary of certain limited aspects of the Italian tax consequences of the acquisition, ownership and disposition of Metal Securities by a Security Holder who is not an Authorised Participant and it does not purport to be a comprehensive description of all the tax considerations that may be relevant to a decision to purchase Metal Securities. This summary does not describe any tax consequences arising under the laws of any state, locality or taxing jurisdiction other than Italy. This summary is based on the tax laws of Italy as in effect on the date of this Supplemental Prospectus, as well as regulations, rulings and decisions of its taxing and other authorities available on or before such date and now in effect. All of the foregoing is subject to change, which change could apply retroactively and could affect the continued validity of this summary. Because it is a general summary, holders of Metal Securities should consult their own tax advisers as to the Italian or other tax consequences of the purchase, holding and disposition of Metal Securities including, in particular, the application to their particular situations of the tax considerations discussed below, as well as the application of state, local, foreign or other tax laws. This summary assumes that the Issuer is not a tax resident nor deemed to be a tax resident of Italy. Provided the Metal Securities qualify broadly as derivative instruments for the purposes of Italian tax law, which they are expected to do, then the following consequences apply to a Security Holder who is not an Authorised Participant, in respect of the net cash proceeds received from a redemption or sale of the Metal Securities over the sum paid by such a holder on their subscription or purchase:
Taxation in Italy. The following is a general summary of current Italian law and practice relating to certain Italian tax considerations concerning the purchase, ownership and disposal of the Securities by Italian resident holders. It does not purport to be a complete analysis of all tax considerations that may be relevant to a decision to purchase, own or dispose of the Securities and does not purport to deal with the tax consequences applicable to all categories of prospective beneficial owners of Securities, some of which may be subject to special rules. This summary is based upon Italian tax laws and practice in effect as at the date of this Prospectus, which may be subject to change, potentially with retroactive effect. Law Decree No. 66 of 24 April 2014, as converted into law with amendments by Law No. 89 of 23 June 2014 published in the Official Gazette No. 143 of 23 June 2014, ("Decree No. 66"), introduced new provisions amending certain aspects of the tax regime of the Notes as summarised below. In particular Decree No. 66 has increased from 20 per cent. to 26 per cent. the rate of withholding and substitute taxes applicable on interest accrued, and capital gains realised, as of 1 July 2014 on financial instruments (including the Securities) other than government bonds.