Client company is selling to a PLC. Deal will involve some day 1 cash and some shares in PLC (that need to be retained for 2-3 years due to terms of the deal). The terms of the deal etc will, almost certainly, result in the 'share for share' provisions (s135 etc) applying to this transaction.
There are a fair few shareholders who do not qualify for Business Asset Disposal Relief as they hold less than 5% of the shares in the client company.
They are, however, nervous about potential changes to CGT in the coming years and so the question is;
Even though BADR is not available - can a s169Q TCGA 1992 election be made in order to crystallise the gain and 'lock in' the 20% CGT rate currently on offer.
Reading s169Q (2) my gut reaction is no........but wondered if any others on here had looked at this previously. Any annswers greatly appreciated.