Luxottica Group, S.p.A. (LUX)

TAX REGIME - HOLDERS OF ORDINARY SHARES

The gross amount of dividend paid to shareholders of Italian listed companies whose shares are registered in a centralized deposit system managed by Monte Titoli S.p.A, who are individuals and are Italian resident for tax purposes, will be subject to a 12.5% final substitute tax, provided the shareholding is not related to the conduct of a business, and if these persons do not hold a “qualified” shareholding. The 12.5% final substitute tax will not be applied only if they timely declare that they satisfy the relevant requirements (eg. qualified shareholding or a shareholding related to the conduct of a business)

This substitute tax will be levied by the Italian authorized intermediary that participates in the Monte Titoli system and with which the securities are deposited, as well as by non-Italian intermediaries participating in the Monte Titoli system (directly or through a non-Italian deposit system participating in the Monte Titoli system), through a fiscal representative to be appointed in Italy.

Italian resident individuals who timely declare that they hold a qualified shareholding or a shareholding related to the conduct of a business, will receive the gross amounts of dividends paid and include dividends in their world wide taxable income, subject to the ordinary income tax rules. The dividend paid to other subjects different from the above mentioned individuals, who are resident in Italy for tax purposes, including those companies subject to IRES/IRPEF and foreign companies with permanent establishment in Italy to which the shares are effectively connected, investment funds, pension funds, real estate investment funds and subjects excluded from income tax pursuant to Art. 74 of Presidential Decree No. 917/86, are not subject to substitute tax. Dividends paid to entities subject to IRES/IRPEF different from individuals holding a non qualified shareholding not related to the conduct of a business, will be subject to the ordinary income tax rules.

Italian law provides for a 27% final substitute tax rate on dividends paid to Italian residents who are exempt from corporate income tax.

Dividend paid to beneficial owners who are not Italian resident and do not have a permanent establishment in Italy to which the shares are effectively connected, are subject to 27% substitute tax rate. However reduced rates (normally 15%) of substitute tax on dividends apply to non-resident beneficial owners, who are entitled to and promptly comply with procedures for claiming benefits under an applicable income tax treaty entered into by Italy. Under the currently applicable Italy-U.S. Treaty, an Italian substitute tax at a reduced rate of 15% may generally apply to dividends paid by Luxottica Group to a U.S. resident entitled to treaty benefits who promptly complies with the procedures for claiming such benefits, provided the dividends are not effectively connected with a permanent establishment in Italy through which the U.S. resident carries on a business or with a fixed base in Italy through which the U.S. resident performs independent personal services.

The substitute tax regime does not apply if ordinary shares representing a “non-qualified” interest in Luxottica Group are held by a shareholder in a discretionary investment portfolio managed by an authorized professional intermediary, and the shareholder elects to be taxed at a flat rate of 12.5% on the appreciation of the investment portfolio accrued at year-end (which appreciation includes any dividends), pursuant to the so-called discretionary investment portfolio regime - regime del risparmio gestito.

Tax regime - Holders of ordinary shares

The gross amount of dividend paid to shareholders of Italian listed companies whose shares are registered in a centralized deposit system managed by Monte Titoli S.p.A, who are individuals and are Italian resident for tax purposes, will be subject to a 12.5% final substitute tax, provided the shareholding is not related to the conduct of a business, and if these persons do not hold a “qualified” shareholding. The 12.5% final substitute tax will not be applied only if they timely declare that they satisfy the relevant requirements (eg. qualified shareholding or a shareholding related to the conduct of a business).

This substitute tax will be levied by the Italian authorized intermediary that participates in the Monte Titoli system and with which the securities are deposited, as well as by non-Italian intermediaries participating in the Monte Titoli system (directly or through a non-Italian deposit system participating in the Monte Titoli system), through a fiscal representative to be appointed in Italy.

Italian resident individuals who timely declare that they hold a qualified shareholding or a shareholding related to the conduct of a business, will receive the gross amounts of dividends paid and include dividends in their world wide taxable income, subject to the ordinary income tax rules. The dividend paid to other subjects different from the above mentioned individuals, who are resident in Italy for tax purposes, including those companies subject to IRES/IRPEF and foreign companies with permanent establishment in Italy to which the shares are effectively connected, investment funds, pension funds, real estate investment funds and subjects excluded from income tax pursuant to Art. 74 of Presidential Decree no. 917/86, are not subject to substitute tax. Dividends paid to entities subject to IRES/IRPEF different from individuals holding a non qualified shareholding not related to the conduct of a business, will be subject to the ordinary income tax rules.

Italian law provides for a 27% final substitute tax rate on dividends paid to Italian residents who are exempt from corporate income tax.

Dividend paid to beneficial owners who are not Italian resident and do not have a permanent establishment in Italy to which the shares are effectively connected, are subject to 27% substitute tax rate. However reduced rates (normally 15%) of substitute tax on dividends apply to non-resident beneficial owners, who are entitled to and promptly comply with procedures for claiming benefits under an applicable income tax treaty entered into by Italy. Under the currently applicable Italy-U.S. Treaty, an Italian substitute tax at a reduced rate of 15% may generally apply to dividends paid by Luxottica Group to a U.S. resident entitled to treaty benefits who promptly complies with the procedures for claiming such benefits, provided the dividends are not effectively connected with a permanent establishment in Italy through which the U.S. resident carries on a business or with a fixed base in Italy through which the U.S. resident performs independent personal services.

The substitute tax regime does not apply if ordinary shares representing a “non-qualified” interest in Luxottica Group are held by a shareholder in a discretionary investment portfolio managed by an authorized professional intermediary, and the shareholder elects to be taxed at a flat rate of 12.5% on the appreciation of the investment portfolio accrued at year-end (which appreciation includes any dividends), pursuant to the so-called discretionary investment portfolio regime - regime del risparmio gestito.