(c) For commercial reasons, Damian believes that it would be sensible to place a new holdi

(c) For commercial reasons, Damian believes that it would be sensible to place a new holding company, Bold plc,

over the existing company, Linden Limited. Bold plc would also be unquoted and would acquire the existing

Linden Limited shares in exchange for the issue of its own shares.

If the new structure is implemented, Bold plc will provide management services to Linden Limited, but the

amount that will be charged for these services is yet to be determined.

Required:

(i) State the capital gains tax (CGT) issues that Damian should be aware of before disposing of his shares

in Linden Limited to Bold plc. Your answer should include details of any conditions that will need to be

satisfied if an immediate charge to tax is to be avoided. (4 marks)