My guess is that these transactions resulted in a zero token balance for the sender and started with a non-zero balance for the recipient. When you store a value, the gas cost varies:
- It costs 20,000 gas if you store a non-zero value where a zero value used to be.
- It costs 5,000 gas otherwise.
- But if you have store a zero where a non-zero used to be, you get a 15,000 gas refund.
The refund is capped to half the consumed gas.
So when transferring all of an account's tokens to an account that already has tokens, the cost should be approximately:
- 21,000 base transaction cost
- 5,000 to update the sender's balance
- 5,000 to update the recipient's balance
- -15,000 refund for setting the sender's balance to zero
That adds up to 16,000 gas. Add to that reading values from storage, logging an event, and other miscellaneous stuff.
I can't give a full accounting for the gas usage, but I believe you'll find that any token transfer under ~30,000 gas has the properties that the sender is sending their full balance and that the recipient already holds some of the token.