(1) If a taxpayer acquires land as a result of a taxable transaction and the tax payable on the transaction is not paid by the due date, the unpaid tax liability becomes an overriding statutory charge over the land.
(2) If a taxpayer who is required to lodge a statement in respect of the acquisition of an interest in a land-holding corporation fails to lodge the required statement, or to pay the tax payable in respect of the transaction, by the due date, the unpaid tax liability becomes an overriding statutory charge over the land of the land-holding corporation and of linked entities.