S.L. 364.19 Art. 14Intra-group transfers. 

Notwithstanding the other provisions of these rules, when a transfer of property to which rule 4, 5 or 8 applies is made to a company, and that company then transfers the property to another company by means of a transfer that is relieved from income tax and from duty on documents and transfers in terms of articles 5(9) and 5A(4)(f) of the Income Tax Act and article 32(6) of the Duty on DOCUMENTS AND TRANSFERS ON CERTAIN PROPERTY 364.19 TRANSFERS Documents and Transfers Act, the condition mentioned in sub-rule (1) of rule 6 or the conditions mentioned in sub-rule (1) and (2) of rule 11, as the case may be, shall continue to apply as if the latter transfer has not taken place, and in the event of a breach in any way of any applicable condition, the two companies shall be jointly and severally liable for the payment of the amount mentioned in sub-rule (2) of rule 6 or in sub-rule (2) of rule 11, as the case may be.