A:  A €1 billion extraordinary distribution on Stellantis common shares, contemplated by the combination agreement entered into by Fiat Chrysler Automobiles N.V. and Peugeot S.A. on December 17, 2019, as amended on September 14, 2020, was approved by the Annual General Meeting of Shareholders of Stellantis held on April 15, 2021 (“Distribution”).

The Distribution entails a payment to the holders of Stellantis common shares of €0.32 per outstanding common share.

A:  The calendar for the Distribution will be as follows:  (i) ex-date on April 19, 2021; (ii) record date on April 20, 2021; and (iii) payment date on April 28, 2021.

A:  The Distribution will be paid out of the capital repayment reserve, which was created by a reduction of the nominal value of the Stellantis common shares in connection with the Faurecia distribution approved by the Extraordinary General Meeting of Shareholders of Stellantis held on March 8, 2021 (“Faurecia Distribution”), to the extent not utilized for the Faurecia Distribution.  If the Distribution exceeds the existing capital repayment reserve, the remaining balance will be paid against profit reserves. 

Based on the current value of the existing capital repayment reserve, the Distribution will be fully paid out of it.

A:  The Distribution will not be subject to 15% Dutch withholding tax up to the amount paid out of the capital repayment reserve, which was created by a reduction of the nominal value of the Stellantis common shares in connection with the Faurecia Distribution, to the extent not utilized for the Faurecia Distribution.  Only the balance, if any, paid against profit reserves will be subject to 15% Dutch withholding tax.  

Based on the current value of the existing capital repayment reserve, the Distribution will be fully paid out of it, therefore, the 15% Dutch withholding tax will not be applicable. 

A:  U.S. and other non-Dutch tax resident shareholders are subject to 15% Dutch withholding tax only for the amount paid against profit reserves. Such 15% Dutch withholding tax is reduced based on tax treaties in force between the Netherlands and the country of residence of the shareholders.  For this purpose, tax residency information would be submitted to the withholding agent by your stockbroker or other financial intermediary. 

However, as the Distribution will be fully paid out of the existing capital repayment reserve, the 15% Dutch withholding tax will not be applicable.   

A:  French tax resident individual shareholders who hold their shares through Euroclear France S.A. or a French-based financial intermediary and who do not qualify for a reduction or exemption under French law are generally subject to 30% withholding, composed of 12.8% personal income tax (“Prélèvement forfaitaire non libératoire” or “PFNL”) plus 17.2% social security levies.  The gross amount of the distributed income will then, in principle, be subject to French personal income tax and social security levies, with the PFNL and the social security levies withheld deducted from the amount effectively due.  

French tax resident shareholders who hold their shares through the Depository Trust Company (“DTC”) or Monte Titoli must self-assess and pay any applicable French personal income tax and social security levies unless a French-based financial intermediary is responsible to withhold the French tax. 

A:  Italian tax resident individual shareholders who hold their shares through Monte Titoli or an Italian-based financial intermediary and who do not qualify for a reduction or exemption under Italian law are generally subject to the 26% Italian withholding tax. 

Italian tax resident shareholders who hold their shares through the DTC or Euroclear France S.A. must self-assess and pay any applicable Italian tax unless an Italian-based financial intermediary is responsible to withhold the Italian tax.

A:  French tax resident individual shareholders who hold their shares through Euroclear France S.A. or a French-based financial intermediary will receive the Distribution, net of 12.8% personal income tax (unless a French withholding tax reduction or exemption applies) and 17.2% social security levies, as applicable, on April 28, 2021.  

All other Euroclear France shareholders will receive 100% of the Distribution on April 28, 2021.

Italian tax resident individual shareholders who hold their shares through Monte Titoli or an Italian-based financial intermediary will receive the Distribution, net of 26% Italian withholding tax (unless an Italian withholding tax reduction or exemption applies), on April 28, 2021.  

All other Monte Titoli shareholders will receive 100% of the Distribution on April 28, 2021.

All other shareholders will receive 100% of the Distribution on April 28, 2021, because the 15% Dutch withholding tax will not be applicable.

A:  Holders of Stellantis common shares that are traded on the Borsa Italiana and/or the Euronext Paris on the record date (April 20, 2021) will receive the Distribution in Euro.

Holders of Stellantis common shares that are traded on the New York Stock Exchange on the record date (April 20, 2021) will receive the Distribution in U.S. dollars at the official EUR/USD exchange rate reported by the European Central Bank as of April 15, 2021 (1.1970).

A:  Shares held by DTC are generally traded on the New York Stock Exchange.  

Shares held by Euroclear France S.A. are generally traded on Euronext Paris. 

Shares held by Monte Titoli are generally traded on Borsa Italiana.  

Please contact your depositary bank, stockbroker or other financial intermediary to obtain this information with respect to your Stellantis common shares.

A:  Holders of Stellantis common shares as of the close of business on the record date (April 20, 2021) are entitled to receive the Distribution.

A:  You should contact your tax advisor and depositary bank, stockbroker or other financial intermediary.