On May 31, 2010, the Italian parliament issued Law Decree No. 78, which provides that a new 10% tax would be imposed on dirigenti, or manager-level employees working in the "financial sector," with respect to bonus income or income received upon the exercise of stock options if that income exceeds three times the rate of the manager's fixed salary.

At the end of February 2011, the Italian Tax Authorities issued Circular 4/E, which provides some guidance with respect to the meaning of "financial sector" under the new law. They have clarified that "financial sector" includes the following entities: (i) banks, (ii) companies and institutions whose corporate purpose consists, exclusively or primarily, of holding shares; (iii) investment management companies (Società di Gestione del Risparmi or "SGR"); (iv) brokerage firms (Società di Intermediazione Mobiliare or "SIM"); (v) financial intermediaries; (vi) entities that issue electronic currency; and (vii) companies that hold and/or manage shares in financial, credit, or industrial companies.

Moreover, companies that primarily or exclusively perform the following activities should also be considered as operating in the "financial sector": (i) lending transactions (including consumer credit, credit with security on mortgage, factoring, assignment of credits pro soluto and pro solvendo, business credit); (ii) financial leasing; (iii) payment services; (iv) issuance and management of means of payment; (v) issuance of guarantees and signing undertakings; (vi) transactions on their own behalf and on behalf of clients on money-market instruments (e.g., checks, bills, deposit certificates, etc.), exchanges, financial futures, and options; agreements on exchange and interest rates, securities; (vii) participation in the issuance of shares and related services; (viii) providing consulting services to other companies in relation to financial structure, industrial strategy, and related issues as well as consulting and services concerning concentration and undertakings' market power; (ix) money brokering services; (x) management and consulting on asset management; (xi) custody and management of securities; (xii) any other activities added to the list attached to the Second Banking Directive (EC Directive 89/646/EEC); and (xiii) collective portfolio management through (a) the promotion, establishment, and organization of mutual funds and the administration of participant accounts; and (b) the management of assets of one's own or third-party collective investment undertakings by means of investment in financial instruments, claims, and other movable or immovable assets.