^ Correct, but my interpretation when applied to a situation if a company was not actively trading then capital gains on sales during the life of the company would presumably be rare as they would be holding the shares long term.

If there were sales then one would think that the gains would be reinvested in other shares etc rather than withdrawn to the shareholders, provided all shares weren't being sold and withdrawn. In which case preparing a capital dividend on liquidation wouldn't be an issue as the company would no longer have any purpose.