The above are the rates of the personal income tax (imposta sul reddito delle persone fisiche, or IRPEF).

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1 Worldwide personal tax guide Italy Local information Tax Authority Italian Revenue Agency Website Tax Year 1 January to 31 December Tax Return due date 30 September Is joint filing possible No Are tax return extensions possible No 2013 National Income Tax Rates Taxable Income Band National Income Tax Rates 1 15,000 23% 15,001 28,000 27% 28,001 55,000 38% 55,001 75,000 41% 75, % The above are the rates of the personal income tax (imposta sul reddito delle persone fisiche, or IRPEF). An additional regional tax applies at rates ranging from 0.7% to 2.03%. An additional municipal tax applies at rates ranging from 0% to 0.9%. A solidarity tax at a rate of 3% is imposed on income in excess of 300,000. The solidarity tax is deductible from income subject to ordinary taxation. This document has been prepared based on the legislation and practices of the country concerned as of 1 July 2013 by EY and published in its Worldwide personal tax guide, Tax legislation and administrative practices may change, and this document is a summary of potential issues to consider. This document should not be used as a substitute for professional tax advice which should be sought for the country of arrival and departure in advance of moving in order to discuss your circumstances. It is your responsibility to disclose your income to the tax authorities. This information is provided by EY in accordance with their Terms and Conditions. Neither HSBC nor EY accepts any responsibility for the accuracy of any of this information. By using this information you are accepting the terms under which EY is making the content available to you. Who is liable? Tax residents of Italy are subject to tax on their worldwide income. Individuals who are not tax resident in Italy are subject to tax on their Italian-source income only.

2 Residence status for tax purposes An individual is considered resident for income tax purposes if, for the greater part of the tax year, they satisfy any of the following conditions: Their habitual abode is in Italy. The centre of their vital interests is located in Italy. They are registered at the Office of Records of the Resident Population in Italy. Italian citizens who move their residence for tax purposes to countries considered to be tax havens ( black list countries) are deemed to be tax resident in Italy in all cases, unless they provide specific evidence of their non-resident status. Income subject to tax Employment income - Employment income includes any compensation, either in cash or in kind, received during a tax period in connection with employment, including any payments received as shares, as acts of generosity or as reimbursement for expenses incurred in the production of the income. Benefits in kind are valued for tax purposes at the normal value, as defined by the Italian tax code. An Italian employer, which qualifies as a withholding tax agent, must withhold income taxes monthly from payments of gross employment income, including benefits in kind. Non-residents are subject to tax on income from employment derived from services performed in Italy and pensions paid by the state or by Italian residents. A special tax regime applies to employees who meet all of the following conditions: The individual is resident for tax purposes in Italy. The employment activity is rendered in a continuous and exclusive manner outside Italy for more than 183 days in a 12-month period. The employee s assignment outside Italy is regulated by an employment contract or by another written agreement signed by the parties. Under the tax regime mentioned in the preceding paragraph, an individual is subject to tax in Italy on a notional employment remuneration, as determined each year by the Italian Ministry of Finance. Directors fees - For tax purposes, directors fees are treated as employment income, subject to progressive income tax rates and withholding tax. This tax treatment does not apply if the services are performed by a professional individual who is registered for VAT purposes. Non-resident directors are subject to a final withholding tax at a rate of 30% on directors fees received. Self-employment income - Self-employment income consists of income from a profession, including accounting, law and medicine. Income from a collaboration is treated as employment income, unless the activity is performed by an individual who is registered for VAT purposes. Residents are subject to tax on worldwide self-employment income. A 20% withholding tax applies to income derived from Italian sources. Non-residents are subject to tax on income derived from services performed in Italy. Non-residents are subject to a final withholding tax of 30% on self-employment income and need not file a tax return.

3 For professionals, taxable self-employment income consists of the difference between compensation received during a tax period and related expenses incurred during the same period, subject to certain limits. Professional income is subject to VAT and to regional tax (IRAP) at a rate of 3.9%. Such rate may vary up to 1% depending on the region of Italy in which the activity is performed. Bookkeeping is required. Real estate income - Income from unrented real estate located in Italy is not subject to income tax. Rental income derived from real property is taxed as ordinary income. Rental income derived from rented real estate located in Italy may be subject to a fixed tax rate (so called cedolare secca) of 19% or 21%, if specific conditions are met. Italian tax residents must report income from real estate located outside Italy in their Italian tax return, unless otherwise provided in an applicable double tax treaty. Real estate is also subject to the tax on Italian real estate (IMU). Business income - Business income consists of income derived from the commercial or industrial activities (entrepreneurial activities) described in the Civil Code. Taxable business income consists of profits disclosed in the financial statements, adjusted for exemptions, disallowed expenses, special deductions and losses carried forward. Business income is determined using the accrual method. Taxable business income is subject to personal income tax. In addition, business income is subject to IRAP, a regional tax on productive activities. IRAP is levied at a rate of 3.9%. Such rate may vary up to 1%, depending on the region of Italy in which the activity is performed. Non-residents are subject to tax on business income from a permanent establishment in Italy. Investment income % (40% for earnings yielded before 1 January 2008) of dividends derived from qualified participations that are received by Italian tax residents from resident and non-resident entities is taxed as ordinary income. Dividends derived from nonqualified participations that are paid by resident and non-resident entities are subject to a separate final withholding tax of 20%. The tax base for dividends on nonqualified participations that are paid by non-resident entities is net of foreign taxes. One hundred percent of the dividends received by an Italian tax resident individual that are derived from an unlisted company resident in a tax haven (as defined by Italian authorities) is taxed as ordinary income. Non-qualified dividends received by an Italian tax resident individual that are derived from a listed company resident in a tax haven (as defined by Italian authorities) are subject to a 20% substitute tax. Dividends paid by Italian resident entities are subject to a 20% withholding tax. Tax treaties may provide a lower tax rate for dividends paid to non-residents. Italian-source interest paid to residents is subject to a final withholding tax at a rate of 20%. Consequently, such interest is not aggregated with other taxable income. Foreign-source interest may be included with other income and taxed as ordinary income or taxed separately at a rate of 20%. Residents are subject to tax on royalties derived from patents, trademarks and know-how. Interest paid to non-residents is subject to a final withholding tax of 20%; tax treaties may provide for a lower tax rate. Interest derived from bank and postal accounts that is paid to non-residents is exempt from tax.

4 Non-residents are subject to a final withholding tax at a rate of 30% on royalties derived from patents, trademarks and know-how. In some cases, this tax is imposed on 60% or 75% of the amount of royalties received form Italian resident entities. Capital gains and losses Securities residents - The taxation of capital gains from the sale of securities not related to business activities varies according to whether the transaction involves a qualified percentage of the company s shares. If the transaction involves a qualified percentage of the company s shares, the ordinary rates are applied to 49.72% (40% if the sale of securities occurred before 1 January 2009) of the gain. The ordinary rates are applied to 100% of the gain if the shares sold relate to qualified shares of a company residing in a tax haven (as defined by the Italian authorities). If the transaction involves a nonqualified percentage of the company s shares, the related capital gain is taxed separately at a rate of a 20%. If the transaction involves nonqualified shares of a listed company residing in a tax haven, the related capital gain is taxed separately at a rate of a 20%. If the transaction involves nonqualified shares of an unlisted company residing in a tax haven, ordinary rates are applied to 100% of the gain. Capital gains derived by non-residents from the sale of securities (including shares representing capital and other similar interests, convertible obligations, stock options and similar rights) not related to business activities are subject to the tax treatment applicable to residents if the securities are issued by an Italian entity. If the taxpayer s losses exceed gains, the difference may be carried forward up to a maximum of 4 years against future capital gains. Real estate - Capital gains derived by individuals from the sale of real estate are taxable if the sale occurs within 5 years after the date on which the property was purchased or built and if the property had not been used as a principal abode for the major part of the period of ownership. The gain is subject to tax as ordinary income, unless, in the transfer deed, the vendor asks the Italian Public Notary to apply a separate final tax at a rate of 20%. Capital gains derived from sales of real estate after the 5-year period of ownership are not subject to tax. Tax on real estate and financial assets Italy introduced a new tax on real estate held abroad for Italian tax resident individuals (imposta sul valore degli immobili situati all estero, or IVIE), which took effect in The tax rate is 0.76%, or 0.4% if the real estate abroad is the tax payer s principal abode. The taxpayer is entitled to a credit for wealth tax paid abroad on the properties. A tax on Italian real estate (imposta municipale propria, or IMU) is partly due to the state and partly due to the municipality where the real estate is located. The standard tax rates are 0.4% for real estate used as principal abode and 0.76% for other real estate. Each municipality can decide whether to increase or decrease the standard rates. However, the increase or decrease cannot exceed 0.2% for the principal abode and 0.3% for other real estate. Italy introduced a new tax on financial assets held abroad by Italian tax resident individuals (imposta sul valore delle attività finanziarie detenute all estero, or IVAFE), took effect from The tax rate is 0.15% from 2013 onwards. In the case of double taxation, it is possible to deduct the wealth tax paid in the country where the financial asset is held.

5 Inheritance and gift taxes Inheritance and gift taxes apply to residents and non-residents. The tax base is related to the value of the assets. The rates depend upon the relationship between the donor and the donee. In addition, cadastral and mortgage taxes apply if immovable properties are inherited or given as a gift. The applicable tax rate is 3%. However, if the real estate inherited or gifted is classified as a primary home, the cadastral and mortgage taxes are imposed at a fixed amount of 168 each. To prevent double taxation of estates, Italy has entered into estate tax treaties with certain countries. In the absence of a treaty, a tax credit may be available for foreign taxes paid on assets located abroad. Social security Italian law provides for a comprehensive system of social insurance. The system is controlled by the government, with various sections administered by separate public institutions, most notably, the National Institute for Social Security (Istituto Nazionale Previdenza Sociale, or INPS). Collective labour agreements provide for compulsory additional coverage through pension and health funds. Both employers and employees usually make contributions to these funds. In general, social security contributions are payable at varying percentages of gross remuneration, depending on the employee s qualification level and the employer s activity sector. In general, employees social security contributions range from approximately 9% to 10% of their gross remuneration. Employers contributions may range from 30% to 35%. Employees with no record of social security contributions before 1 January 1996 are subject to pension contributions on gross income up to a maximum of 99,034 for Self-employed individuals, directors and consultants must enrol with the so-called Gestione Separata (INPS), unless other specific rules apply (for example, certain professionals, such as lawyers, engineers and accountants, are required by law to enrol in specified pension plans). The contributions to the INPS are calculated at a flat rate ranging from 18% to 27.72% on annual income up to a maximum of 99,034 for In addition, foreign citizens, such as non-resident directors, must enrol with the INPS. Under certain circumstances, a totalization agreement may provide an exemption from the abovementioned contributions. Tax filing and payment procedures A failure to make a filing is subject to a penalty ranging from 258 to 1,032 (if no income tax is due) or ranging from 120% to 240% of the tax due, plus interest (if a tax liability arises). If the tax return is filed within up to 90 days after the due date, under a special procedure to reduce penalties called ravvedimento operoso, the ordinary penalties mentioned above may be reduced by 1/10. Income tax must be paid by 16 June for income earned in the preceding calendar year. Advance tax payments must be made, equal to 99% of the preceding year s tax liability.

6 Italian tax resident individuals must declare in Italy their investments held outside Italy at the end of the relevant tax year for monitoring purposes. This declaration is made through the filing of the foreign investment return (RW Form).The RW form is filed jointly with the Italian income tax return. Penalties ranging from 10% to 50% apply in the case of omitted or incorrect filings of the RW Form. Double tax relief and tax treaties Foreign taxes that can be considered to be definitively paid by resident taxpayers on foreign-source income may be credited against personal income tax. The maximum amount of foreign tax that may be credited is the full amount of Italian tax attributable to the foreign-source income, based on the proportion of the foreign-source income to the aggregate income. However, the foreign tax credit cannot exceed the net income tax due from the taxpayer. Italy has entered into double tax treaties with 91 countries.

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