For the purposes of the Finance Act 1999, 'transfer on sale' includes every instrument, and every decree or order of any court or of any commissioners, by which any property, or any estate or interest in any property, upon the sale1 thereof2 is transferred to or vested in a purchaser, or any other person on his behalf or by his direction3.
An instrument may be a transfer on sale notwithstanding that a constructive trust of the property transferred existed in the purchaser's favour before the transfer was executed and notwithstanding that the transfer was executed by persons other than the
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