Although it is not mentioned in any of the RFCs, the universal way of using 
REFER for call transfer is to send the REFER within the dialog that you are 
transferring, the dialog that was created by the initial INVITE.  "Out of 
dialog REFER" is rarely used for call transfer.

It is very uncommon to have a subscription and an "INVITE dialog usage" (that 
is, phone call) within the same dialog -- with the exception of the 
subscription that is created by a REFER within the INVITE dialog usage.

Dale

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