33. In the case of a deemed transfer, the transferee shall not be permitted to defer payment of the duties unless the statement contemplated in section 27 is made in authentic form enminute, is registered and contains the following particulars:(a) the undertaking contemplated in section 29 or the statement contemplated in section 31; and
(b) a stipulation of hypothec on the land, by the transferee in favour of the Minister, for the amount of the duties of which payment is deferred.