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Lura, I think your debates have been when the appraisal is tried to be used to get a loan from a bank, and yes the bank say, no way. In Qld when transferring for one person to another, and the transaction is not considered "arms lengtht" then the Office of State Revenue, will accept letters of...

Wylie, my transfer was in 2005 or 2006. Perhaps it was either me or my solicitor being a bit anal, and not wanting a later issue. Knowing a few agents, getting the letters was not difficult. If pays to check with the department at all times, to be up to date. I still believe this may vary state...

Wylie, my recent experience in Qld was, we needed, 3 agents and yes each with 3 comparables (they may be the same comparables). Msapples, if you contact the relevant Vic department, they will give you their requirements. Good luck.