Article 3
1. The exemption from the indirect taxes on the transfer of the Siremar business branch to SNS constitutes State aid to Siremar within the meaning of Article 107(1) TFEU. The State aid was unlawfully put into effect by Italy in violation of Article 108(3) TFEU. 2. The payment by SNS of a fixed fee for the registration of the contract for the purchase of the Siremar business branch pursuant to the 2010 Law, instead of the fee ordinarily due under national law, constitutes State aid to SNS within the meaning of Article 107(1) TFEU. The State aid was unlawfully put into effect by Italy in violation of Article 108(3) TFEU. 3. The exemption from corporate income tax of the proceeds from the sale of the Siremar business branch to SNS constitutes State aid to Siremar within the meaning of Article 107(1) TFEU. The State aid was unlawfully put into effect by Italy in violation of Article 108(3) TFEU. 4. The aid referred to in paragraphs 1, 2 and 3 of this Article is incompatible with the internal market. 5. At the time of adoption of this Decision, Italy has not yet paid out the aid referred to in paragraph 3 of this Article.