Section 10.- Notwithstanding the provisions of Section 6(1) of this companies and limited liability companies, even where they operate as sole proprietorships, shall be exempt from tax levied on company profits provided that the company taking over or the new company has its registered 1719 Code and in the case of total or partial sale, transfer or termination of the activity, the net capital gains, i.e. those obtained after the deduction, if any, of realized losses, sustained in the transfer of fixed assets, and allowances in exchange or as compensation for the cessation of the practice of the profession (activity) or transfer of the clientele, are taxed as follows:

• For half of their value when the cessation, transfer or termination takes place less than five years after the creation, purchase of the business or clientele;
• For a third or their value otherwise.