If a charge is created under section 302A in favour of the Commonwealth,
the Commonwealth's charge:
- (a)
- is subject to every * encumbrance on the
property that came into existence before it and that would otherwise have
priority; and
- (b)
- has priority over all other encumbrances; and
- (c)
- subject to section 302B, is not affected by any change of ownership
of the property.