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ENAV S.p.A. Financial Statement

10. Current and non-current tax receivables

Non-current tax receivables were unchanged compared to 2014, and amount to €
23,164 thousand. They refer to the receivable for the higher corporate income tax
(IRES) paid in the years 2007/2011 arising from IRAP not being deducted related to
personnel and similar costs, as per the application for a refund filed on 6 March 2013.
Specifically, the entitlement to a refund is based on Article 2 of Legislative Decree
201/2011 that permits IRAP to be deductible analytically from corporate taxable
income, which had previously only been permitted to the extent of 10 percent of
the tax paid; this Decree was subsequently integrated with Decree-Law No. 16 of
2012 under Article 4, paragraph 12, in order to extend this possibility to prior tax
periods, with effect from the 2007 tax period. Regarding the timescale for receiving
the refund, given that the Tax Revenue Office envisions making payment starting
from the earliest tax years and on the basis of the order in which the electronic flows
are transmitted, and it establishes criteria in the cases in which it does not have fully
available funds, the receivable has been classified prudently as a non-current asset.
Current tax receivables amount to € 79,785 thousand and comprise the receivables
detailed in the table below.

Due from the tax authorities 31.12.2015 31.12.2014 Change
for VAT 61.106 60.990 116
0 9.912
IRES for the year 17.025 1.605 (9.912)
1.654 2.064 15.420
IRAP for the year 79.785 74.571
(410)
Receivable for other current 5.214
taxes

Total

The receivable due from the tax authority for VAT for € 61,106 thousand underwent
a net increase of € 116 thousand referring to a decrease of € 21,415 thousand for
the receipt of a VAT refund the Company requested in month of February 2014 and
referring to the 2013 tax period including interest, accrued interest recorded on the
VAT receivable to be refunded for the 2012 and 2014 tax periods amounting to € 765
thousand and VAT for the period for € 20,734 thousand. The VAT refund request at
the end of 2015 stands at € 40,280 thousand. It is noted that the Tax Revenue Office
has advised of the successful outcome of the audit on VAT requested as a refund for
2012, and ordered that € 20 million plus interest be paid. A refund of € 20.8 million
was requested with the filing of the 2015 VAT return submitted in February 2016.
The IRES receivable reverted to a nil balance in the year, given that the 2015 related
tax was higher than the receivable recorded. The relevant amount is recognised
under tax payables.

ENAV - Annual financial report 2015 203