In accordance with the provisions of Argentine Personal Assets Tax Law No. 23,966 Pampa Energía is required to pay, as substitute taxpayer, the personal assets tax payable by all of the Company’s shareholders who are subject to the tax. This include all of Pampa Energía’s shareholders, except for Argentine companies (including AFJPs) and holders of ordinary shares from Switzerland, Chile and Spain, all of which are free of this tax.
In order to preserve the Company‘s equity and, mainly to afford an equitable treatment to all its shareholders, Pampa Energía implemented for fiscal years from 2007 to 2010 a mechanism considered to be an effective and efficient tool, which consisted in declaring the distribution of an early dividend to offset the amount of personal asset tax payable by Pampa to the Argentine Tax Authority (Administración Federal de Ingresos Públcos – AFIP), in its capacity as substitute taxpayer of such tax.
For more information, please refer to the section on Dividend History.