GENERAL MEETING DRAFT - Bankier.pl

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"Income tax applies only at the domestic level in that there is no tax or category of taxes applicable
outside the tax systems of each individual country, and there is no tax applicable to consolidated
transnational income. When reference is made to consolidated income, the reference in any case is
always to income consolidated on a purely domestic basis.
Out of the main countries where the UniCredit Group operates, there are domestic consolidated tax
schemes in Italy, Germany, Austria and the UK, but no such structures exist in Ireland, Poland, Bulgaria,
Turkey or other CEE countries.
Consolidated tax scheme regulations also differ from one country to another, sometimes substantially.
Nonetheless, the main benefit common to national consolidated tax schemes is the right to offset
algebraically the income and losses of companies belonging to the same group.
It should also be noted that the requirements for participating in a national consolidated tax scheme do
not always coincide with the requirements for participating in a banking or other group for the purposes of
accounting consolidation based on international accounting standards (IFRS).
Each individual country has an autonomous tax system in which both the determination of the tax basis
and the applicable tax rates differ. Especially in the area of income tax, to this day rather significant
differences still exist between national tax systems, even within the European Union itself.
With regard to tax rates, corporate income is taxed at a rate of 10% in Bulgaria, 16% in Hungary and
Romania, 25% in Austria, 27.5% in Italy, – where, however, the regional tax on productive activities
(IRAP) must be added, the nominal rate of which (3.9%) applies to a rather broad tax base – 19% in
Poland, 20% in Turkey and 28% in the UK.
This framework makes it essentially impossible to compare the consolidated tax position with the position
of the individual companies that make up the Group.
Furthermore, the typical elimination of intragroup items in accounting consolidation does not make any
reference to income tax, which is limited to each individual company.
Bearing in mind that there were no major changes in tax rates in any of the countries where the Group
operates, the most significant tax aspect that distinguishes 2009 from 2008 is the absence of
extraordinary items comparable to the exemption for goodwill that occurred in Italy in 2008, based on
paragraphs 10 and 11 of Article 15 of Decree Law No. 185 of November 29, 2008, which essentially
resulted in the 2008 consolidated tax rate of 9.3%.
Conversely, the tax rate of 30.4% in 2009 is a normal tax rate for the Group in the absence of any such
extraordinary events.
The decision to exempt goodwill in the 2008 budget also produced an extraordinary tax payment of
�1,384,307,604.00 in Italy on June 16, 2009.
2009 CONSOLIDATED REPORTS AND ACCOUNTS
314