(v) paragraph II of the Agreement (Tax Event) shall not apply to any Transaction by
virtue of any Italian Bonds ceasing to be Securities in respect of which a deduction or
withholding on account of Italian tax is required to be made in respect of a payment
of Income to such an owner as is referred to in subparagraph (i) above.
(b) For the purposes of this paragraph -Italian Bonds- means any Securities which are issued by the
Italian government or local authorities (or the Securities which for Italian tax purposes am treated
likewise) or by other entities and to which the provisions of Legislative Decree no. 239 of 1st
ApriL 1996, as amended, granting a special tax treatment will apply.
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t()nlicicneal
CONFIDENTIAL — PURSUANT TO FED. R CRIM. P. 6(e) DB-SDNY-0115676
CONFIDENTIAL SDNY_GM_00261860
EFTA01456474