Art REPUBLIC OF SAN MARINO DECREE - LAW 28 June 2012 67 We the Captains Regent of the Most Serene Republic of San Marino Having seen the need and urgency referred to in Article 2, paragraph 2, point b) of the Constitutional Law of 15 December 2005 .183 and Article 12 of the Qualified Law 184 of 15 December 2005, namely: - the need to promote and give incentives for tax, corporate reorganization and concentration and aggregation of entities operating in the financial sector aimed at overcoming the current industry weaknesses and at the same time preparatory to a strengthening and revitalization of the companies themselves; - The urgent need to promptly introduce extraordinary standards aimed at those objectives, pending the entry into force of the tax reform ,; Given the decision of the Congress of State # 1 adopted at its meeting on 26 June 2012; Having regard to Article 5, paragraph 2, of the Constitutional Law no. 185/2005 and Article 9 and Article 10, paragraph 2, of the Qualified Law n.186 / 2005; Promulgate and publish the following decree-law: URGENT MEASURES IN SUPPORT OF THE FINANCIAL SYSTEM Single Article The contributions of assets or businesses or business units in favor of other companies belonging to the same group of San Marino, made in the year 2012, when the contributor San Marino is the company under Law 17 November 2005 n. 165, are not speculative purposes and therefore any capital gain is exempt in the application for income tax purposes of Law 13 October 1984 n. 91. The goodwill recognized as a result of the transactions referred to in the previous paragraph is deductible and governed by the provisions of Decree 20 January 1986 n. 3. The losses incurred by the acquiring company in the last three years prior to the date of the contribution of assets or businesses or business units received from other companies within the same group of San Marino, in the case of San Marino companies under Law 165 of November 17, 2005 , and not used for tax purposes, they will be fully deducted from taxable income over the next ten years. The act of contribution of assets or businesses or business units in favor of other companies of San Marino under Law 17 November 2005 n. 165, belonging to the same group and entered into two after the entry into force of this Decree and by the date of December 31, 2012, at variance with the law 25 October 1981 n. 85 and subsequent amendments thereto, shall be subject to registration tax in the fixed amount equal to € 1,200.00 and transcription and perfecting the extent of 0.10% each. Given at Our Residence, this day of 28 June 2012/1711 THE CAPTAINS REGENT Maurizio Rattini - Italo Righi p. THE SECRETARY OF STATE FOR INTERNAL AFFAIRS The Secretary of State Antonella Mularoni