Press Release

Statement by a Fiat Industrial spokesperson

Certain articles appearing in the press and statements from Italian politicians and trade union representatives seem to have given rise to the idea that, following the merger of Fiat Industrial and CNH, the tax domicile of the new company will be transferred from Italy to the United Kingdom with a material impact on tax revenues in Italy.
Any assertions to that effect are absolutely without foundation.
To begin with, CNH Global N.V. has been resident in the Netherlands for many years. In Italy and elsewhere, Group companies maintain a legal presence in the various countries where they operate and will continue to pay taxes in those jurisdictions as before.
Therefore, the assertion that Italy would lose out on more than €500 million in tax revenues is simply false. That figure is based on an aggregate of the taxes payable by individual Group companies on the basis of local tax laws. In fact, 46% of that amount relates to companies operating in North America, 11% to companies in Latin America, and 27% to companies in Europe, with only 5% of the total attributable to the Group's activities in Italy.
The selection of tax domicile for the NewCo is fully consistent with all applicable regulations and a ruling has been requested from the competent authorities in the Netherlands and the United Kingdom, with which the NewCo will comply.
The reasons underlying the decision as to which jurisdiction the NewCo is to be based in are fully consistent with the main objectives of the transaction: establishment of a global player in the capital goods sector that is attractive to international investors.
After having examined the various bilateral treaties against double taxation, the Group believes that establishing its tax domicile in the United Kingdom would put NewCo's shareholders on the same level ground as those of its principal competitors.
Turin, 22 May 2013

Fiat Industrial S.p.A.

Via Nizza 250, 10126 Torino

Tel. +39 011 006 3088, Fax +39 011 006 3798 mediarelations@fiatindustrial.com www.fiatindustrial.com

distributed by