FORM OF CRAVATH, SWAINE & MOORE LLP TAX OPINIONFiat Chrysler Automobiles N.V. • July 24th, 2020 • Motor vehicles & passenger car bodies
Fiat Chrysler Automobiles N.V. (“FCA”), a Dutch public limited liability company, and Peugeot S.A. (“PSA”), a French société anonyme, have entered into the Combination Agreement, dated as of December 17, 2019 (the “Combination Agreement”), pursuant to which FCA and PSA will effect a cross-border merger of PSA into FCA (the “Combination”). We have acted as your tax counsel in connection with the prospectus included in a registration statement filed with the Securities and Exchange Commission (“SEC”) on Form F-4 (Registration No. [●]) on the date hereof (the “Registration Statement”) in connection with the Combination.
