I believe you are correct. It seems that the meaning/definition...

I believe you are correct. It seems that the meaning/definition of 'sale' &/or 'transfer' may be an issue for some.
I have done a number of off-market transfers to family & related entities & offer the following observations.

I am willing to be corrected but, IMHO, if the aforementioned 'off-market transfer' was a 'gift' to a family member, or if indeed it was a 'sale' that was settled off-market rather than by/via a Registry, either way it was a transaction with a commercial value - it would have to have been to be 'booked' as a loss for tax purposes. To book a loss the shares would (a) have to have been 'gifted'/'disposed of'/'sold' at a price less that the 'buy', and (b) be recorded as such, ie a disposal at a nominated value (in this case 29c) - ie a 'sale'. TMK, it is not possible to merely transfer shares without their being an agreed SP value that applies to the disposal plus the acquisition. The term 'transfer' pertains primarily to the manner of 'settlement' and does no denote a value-free transaction (even if no money changes hands).

Many metaphors could illustrate ... but, one should do. If someones intended to 'fish' all day ... & they did so without catching anything the description of their day's activity does not change. In a similar way, the term 'sale' is apt for the aforementioned transaction, irrespective of whatever money/goods/services may have been involved in that transaction