A transfer is still a sale - it is - it is a change of ownership, the ATO treat it as a capital event. But in any case, it is difficult to see the full story from the top 20. Transfers to an interlinked entity like from yourself to your trust or super fund are less concerning, and if these other entities do not qualify for being on the top 20 list then we wouldn't see them.
Thank you for purchasing and providing the lists and some comment for us Columbo, it was interesting.