Originalmente inviato da
perpetuals
l'ultima unicredit anche volendo viene tassata al 27%
ha ragione Drago , non c'e' nessun motivo per tassarla al 27% ( la tassazione 12,5% e' indicata nel prospetto pagina 104)
ITALIAN TAXATION
Tax treatment of the Notes
Legislative Decree No. 239 of 1 April 1996, as subsequently amended (Decree No. 239) provides for
the applicable regime with respect to the tax treatment of interest, premium and other income
(including the difference between the redemption amount and the issue price) from notes falling within
the category of bonds (obbligazioni) or debentures similar to bonds (titoli similari alle obbligazioni)
issued, inter alia, by Italian resident banks.
The Italian tax authorities have clarified (Revenue Agency Circular No. 4/E of 18 January 2006) that
bonds may have a maturity which is not scheduled at a specific date, but it is linked to the maturity of
issuing company or to the liquidation thereof, if the company has been set -up with an undetermined
maturity pursuant to Article 2328 (2), No. 13 of the Italian Civil Code.
Where the Notes have an original maturity of at least 18 months and an Italian resident Noteholder is
(a) an individual not engaged in an entrepreneurial activity to which the Notes are connected (unless
he has opted for the application of the risparmio gestito regime – see “—Capital Gains Tax” below),
(b) a non-commercial partnership, (c) a non-commercial private or public institution, or (d) an investor
exempt from Italian corporate income taxation, interest, premium and other income relating to the
Notes, accrued during the relevant holding period, are subject to a withholding tax, referred to as
“imposta sostitutiva”, levied at the rate of
12.50 per cent. In the event that the Noteholders described
under (a) and (c) above are engaged in an entrepreneurial activity to which the Notes are connected,
the imposta sostitutiva applies as a provisional tax.