Current income tax liabilities of €175 million (€11 million at 31 December 2010) saw an increase of €164 million compared to 31 December 2010, due mainly to additional IRES payables of €169 million (Robin Hood Tax). The implementation of this tax, which applies from 2011 to the natural gas transportation and distribution segments, follows the tax measures brought in by Decree Law No. 138 of 13 August 2011, converted into Law No. 148 of 14 September 2011. In particular, Article 7 of said Decree amended Decree Law No. 112 of 25 June 2008 (converted into Law No. 133 of 6 August 2008) establishing an additional IRES (the Robin Hood Tax) for companies operating in the fields of hydrocarbons exploration and development, oil refining, production and sale of petrol, oil, diesel, lubricants, liquefied natural gas and liquefied petroleum gas, and the production or sale of electricity, making provision, from the current financial year, for:
- extending the scope of the Decree to include companies operating in the fields of transmission, dispatch and distribution of electricity and transportation and distribution of natural gas for financial years 2011, 2012 and 2013, and increasing in the rate of additional tax from 6.5% to 10.5%;
- changes to the ceiling above which the additional tax applies, identified, with reference to the previous financial year, as revenue of €10 million and taxable income of €1 million, to replace the previous threshold of €25 million.
As a result of the measures in question, Snam companies operating in the natural gas transportation and distribution segments are subject to the additional IRES at a rate of 10.5% for financial years 2011, 2012 and 2013 and 6.5% from 2014.