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Clifford Chance

Clifford Chance


Important opportunities for the market of short-term bonds and securitisation notes in Italy

7 September 2011

New tax legislation should open up great opportunities for Italian issuers to
tap into the short term capital markets by removing the withholding tax
discrimination currently existing vis-à-vis long term bonds.

One of the (possibly unintended) consequences of the new measures
proposed by the Italian Government to reform the taxation of interest (and
capital gains) on securities is a significant widening of the scope of the tax
regime applicable under Legislative Decree 239 of 1 April 1996 (the “239
Regime”). The new measures are contained in a decree law currently
before Parliament for conversion into law. Once the conversion is
accomplished as expected (in the next few weeks), the new regime will
apply as of 1 January 2012.

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