Instrumentos y métodos para recolectar información

18.1 Tax expense (income) related to profit or loss from continuing operations: breakdown

P&L ITEMS/SECTORS 2013 2012

1. Current tax (-) (393,507) (2,277,759)

2. Adjustment to current tax of prior years (+/-) 93,688 211,295

3. Reduction of current tax for the year (+) - -

3. bis Reduction of current tax assets for tax credits - lawn. 214/2011(+) 31,904 588,386

4. Changes to deferred tax assets (+/-) 2,625,982 4,589,433

5. Changes to deferred tax liabilities (+/-) 13,606 20,016

6. Tax expense for the year(+/-) 2,371,673 3,131,371

18.2 Reconciliation of theoretical tax charge to actual tax charge

2013 2012

Total profit or loss before tax from continuing operations (item 250) (13,972,784) (3,351,154)

Theoretical tax rate 27.5% 27.5%

Theoretical computed taxes on income 3,842,516 921,567

1. Different tax rates - -

2. Non-taxable income - permanent differences 1,380,107 590,437

3. Non-deductible expenses - permanent differences (3,028,427) (281,526)

4. Different fiscal laws/IRAP 303,854 (310,067)

a) IRAP (italian companies) 326,054 (269,250)

b) other taxes (foreign companies) (22,200) (40,817)

5. Prior years and changes in tax rates 58,043 210,433

a) effects on current taxes 69,007 211,295

- tax loss carryforward/unused tax credit 93,689 -

- other effects of previous periods (24,682) 211,295

b) effects on deferred taxes (10,964) (862)

- changes in tax rates - -

- new taxes incurred (+) previous taxes revocation (-) - -

- true-ups/ adjustments of the calculated deferred taxes (10,964) (862)

6. Valuation adjustments and recognition of deferred taxes - 3,922,957

a) deferred tax assets write-down - -

b) deferred tax assets recognition - 3,922,957

c) deferred tax assets non recognition - -

d) deferred taxes non-recognition according to IAS 12.39 and 12.44 - -

e) other - -

7. Amortization of goodwill - -

8. Non-taxable foreign income - -

9. Other differences (184,420) (1,922,430)

163 UniCredit S.p.A. · 2013 Reports and Accounts

Income taxes are recognized in accordance with the provisions of IAS 12. The tax charge consists of current and deferred taxes, mainly determined in accordance with the current provisions on IRES and IRAP tax, and separate taxation “for transparency” of CFCs.

IRES tax is calculated by making certain upward or downward adjustments to the profit for the year to determine the taxable income. These tax adjustments are made, as required by the provisions of the Italian Income Tax Code (TUIR), in relation to the non-deductibility of certain expenses or the non-taxability of certain income.

The tax rate applied to the taxable income is 27.5%.

The above-mentioned tax adjustments may be “permanent” or “temporary”.

The “permanent” adjustments relate to expenses/revenues that are totally or partially non-deductible/non-taxable.

The “temporary” adjustments, on the other hand, relate to expenses or income whose deductibility or taxability is deferred to future tax periods, until the occurrence of particular events or spread in equal amounts over a predefined number of years.

The presence of “temporary” adjustments leads to the recognition of deferred tax assets (for income to be deducted) or deferred tax liabilities (for expenses to be taxed).

The purpose of the recognition of deferred tax assets and liabilities is to reconcile the different tax period established by the TUIR and the accounting period in the financial statements disclosure.

For 2013, Law no. 5 of January 29, 2014 (converting Decree Law 133/2013, known as the “IMU - Bank of Italy Decree”) set an additional amount of 8.5% payable for banks, on an individual basis, and to be calculated on IRES income tax taxable income obtained not taking into account the tax increases arising from the write downs on receivables whose deductibility is deferred to subsequent years.

For IRES tax purposes - subject to an option to be applied for from the Italian Revenue Agency - the tax can be paid at the level of national tax consolidation rather than on an individual basis.

All the Italian companies for which there is a relationship of control can adhere to the tax consolidation, which enables the payment of tax on a single taxable amount consisting of the algebraic sum of the taxable amounts of the individual companies adhering to the consolidation.

The tax rate is 27.5%.

Also within the IRES tax, a separate taxation “for transparency” has been established for tax incomes, recalculated in accordance with the provisions of the TUIR, of the direct and indirect foreign subsidiaries resident in tax havens (referred to as CFCs or Controlled Foreign Companies). The tax rate is 27.5%.

The IRAP tax, on the other hand, is a tax on production, linked to the algebraic sum of the accounting items identified by Legislative Decree 446/97, to which clearly identified upward and downward adjustments (different to those for IRES tax) are to be made. To mitigate the impact of the non- deductibility by principle of the cost of labor, a specific deduction has been established, known as the “tax wedge”.

This tax is applied on a regional basis. A national rate of 4.65% has been established, to which each Region can independently add an increase of 0.92%, up to a theoretical rate of 5.57% (plus an additional 0.15% for Regions with a health budget deficit).

The tax is calculated by apportioning the overall value of production among the various regions where the productive activities are carried out (for banks the apportionment is made on the basis of the regional distribution of the deposits) and applying the respective regional rate to the individual portions identified.

Income taxes for 2013 show a positive value of €2,371,7 million, representing a decrease in numeric terms compared to the positive value of €3,131.4 million in 2012.

In actual fact taxes improved compared to 2012, since that financial year included the positive impact of approx. €2,000 million of goodwill detaxation of trademarks and other intangible assets relating to controlling interests recognized in the consolidated financial statements (art. 15, para. 10, of Decree Law No. 185 of November 29, 2008 and art. 23 of Decree-Law No. 98 of December 29, 2011) and the benefit of €151.9 million for reimbursement applications submitted (art. 2, paragraph 1, of Decree Law No. 201 of December 6, 2011) relating to the recovery via IRES income tax of IRAP corporate tax paid for labor costs.

Current IRES income tax recorded modest taxable income, which allowed only minimal recovery of the tax loss of Capitalia (approx. €1.1 million). IRAP corporate tax, albeit with more significant taxable income, recorded a sharp decline following the introduction (Stability Law for 2014), also for the

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Company Accounts and Annexes I Notes to the Accounts

2013 Reports and Accounts · UniCredit S.p.A.

Part C - Income Statement (Continued)

purposes of this tax, of the possibility of deduction over 5 years of write downs on receivables. IRAP corporate tax due was therefore reduced to -€136 million against -€244.8 million in 2012 while deferred tax assets of €426.9 million were recognized.

In relation to the new (Stability Law for 2014) possibility to also convert deferred tax assets recognized for IRAP corporate tax purposes into tax credits, the actual average IRAP corporate tax rate for 2013 was supplemented by the amount of deferred assets previously recognized in the financial statements - for prudential purposes - at the lower rate. The adjustment resulted in contingent assets in the income statement of €61.5 million. In 2013 financial statement a substitute tax debt for € 184.4 million have been booked, related to Bank of Italy revaluation subsequent to L. 20/1/2014 n. 5 (which has converted DL 133/2013, so called “Decree IMU - Bank of Italy”). As clarified by n 4 02/24/2014 Agenzia delle Entrate circular, 12% substitute tax is due on the difference between increased book value subsequent to revaluation and fiscal value.

Payment of the additional of 8,5% is, however, not due, since the taxable income on which this must be applied is negative.

Lastly, please note that, pursuant to Article 2, paragraphs 55 to 58, of Law Decree No. 225 of December 29, 2010, since the Company closed the year 2012 with an accounting loss in the financial statements of €219.7, the deferred tax assets recognized in previous years were converted, as required by law, into tax credits against value adjustments on receivables and goodwill totaling €31.9 million. This amount had no impact on the income statement.