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185000000 IT Holding Finance SA

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<strong>IT</strong> HOLDING S.p.A. Notes to the consolidated financial statements for the year ended December 31, 2002<br />

In 2001, a preliminary assessment report was served for 1998, 1999, and 2000, relating to the same irregularities<br />

found in previous years. No notices of assessment have been issued to date.<br />

The acquisition contract for M.A.C.—Manifatture Associate Cashmere S.p.A. (formerly FINCASHMERE S.p.A.)<br />

and subsequent integrations provides that the sellers are liable for tax contingencies pertaining to years up to 1998 and<br />

for a maximum amount of Euro 4,390 thousand, with an excess clause of Euro 2,324 thousand. On October 30, 2003,<br />

an agreement was signed with the sellers on the basis of which they terminate the above guarantee and pay M.A.C.—<br />

Manifatture Associate Cashmere S.p.A. Euro 300 thousand. The company adjusted the provision by this amount, and<br />

thus a total of Euro 3,046 thousand, which reflects the maximum potential tax risk on the basis of updated estimates<br />

made, including the opinions expressed by external consultants. — GIANFRANCO FERRÉ S.p.A.<br />

In 2000, a preliminary assessment report was served, disputing certain irregularities in form and substance relating to<br />

1998, 1999, and the period up to May 31, 2000 for IRPEG and VAT tax purposes and relating to 1998 and 1999 for<br />

IRAP purposes. Two years later, the company received a notice of assessment relating to 1997 for VAT purposes. In<br />

2003, the company settled this potential litigation, pursuant to article 15, of Law no. 289/2002.<br />

In 2004, the company decided to settle the irregularities noted by reaching an agreement on the potential dispute<br />

pursuant to article 15, of Law no. 289/2002. The cost of settlement of Euro 240 thousand was fully covered by the tax<br />

provision. — <strong>IT</strong> HOLDING S.p.A.<br />

During the year, the company received an assessment from the Molise tax authorities. A loss of approximately Euro<br />

150,000 could arise from the assessment, which will be settled for approximately Euro 37,000, by filing a<br />

supplementary tax return in accordance with article 8 of Law no 289/2002. — <strong>IT</strong>TIERRE S.p.A.<br />

The tax provision of <strong>IT</strong>TIERRE S.p.A., amounting to Euro 205 thousand, relates to the following tax disputes.<br />

In 2003, disputes relating to direct taxes and VAT for 1995 and 1996 were settled in accordance with 16 of Law<br />

no. 289/2002 (“settlement of pending disputes”).<br />

In 2001, the tax police performed an inspection leading to three preliminary assessment reports alleging VAT<br />

irregularities in form and substance in 1997, 1998, 1999, and 2000 up to February 22. Only 1997 was assessed and<br />

was subsequently settled in 2003 as a “potential dispute” in application of article 15 of Law no. 289/2002. No other<br />

notices of assessment have been issued to date. The estimated potential tax liability should not significantly impact the<br />

company’s financial position and results is not expected to exceed the amount accrued at year end 2003. — <strong>IT</strong>J S.p.A.<br />

(merged into <strong>IT</strong>TIERRE S.p.A. in 2002)<br />

In 2000, this company received a preliminary assessment report from the Regional Tax Office of Campobasso<br />

relating to the 1997 and 1998 tax periods. The irregularities assessed for 1997 were settled in 2003, as a “potential<br />

dispute” under article 15 of Law no. 289/2002. No notice of assessment has been received for 1998.<br />

During 2002, following inspections performed by the Customs Authority of Campobasso, the company was served<br />

preliminary assessment reports in which certain irregularities were contested in relation to sales of assets in EU and<br />

non-EU countries. The company settled these as a “potential dispute” under article 15 of Law no. 289/2002. — FD<br />

S.p.A. (merged into <strong>IT</strong>J S.p.A. in 2001)<br />

In 2002, the company received a preliminary assessment report from the Regional Tax Office of Campobasso alleging<br />

certain irregularities in terms of form and substance with regard to direct and indirect taxes in 1999 and 2000. The<br />

company has not received any notices of assessment.<br />

The estimated potential tax liability should not significantly impact the company’s financial position and results and<br />

should not exceed the amount accrued at year end 2003. — <strong>IT</strong>TIERRE FRANCE S.A.<br />

F- 123

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