You are the tax consultant of Thuthuka Consultants (Pty) Ltd. You have been approached to assist the client to determine whether they are a public company or a private company for tax purposes. The company, Cell Technologies (Pty) Ltd is not quoted on the stock exchange. The shareholder's register revealed the following shareholding: 1. 5% PREFERENCE SHARES: a. 20% each is held by both Mr PwC as well as Mr Puma. b. Namdeb Mining Ltd, a diamond mining company, as well as Mr Nike hold 5% each of the preference shares. c. 20% of the preference shares are held by Mr Anderson. d. 28% is held by Samsung (Pty) Ltd. e. 2% is held by Mr Forbes, the director of Cell Technologies (Pty) Ltd. 2. ORDINARY SHARES: a. Each of the following shareholders hold each 2% of the ordinary shares; Sunshine Gold (Pty) Ltd, a gold mining company, Mr Forbes, Mrs Nike (Director of Cell Technologies (Pty) Ltd), Mr Puma (Director of Cell Technologies (Pty) Ltd), Namdeb Mining Ltd and City of Windhoek. b. The minor of Mr Nike holds 10% of the ordinary shares. c. Mr KFC, Mr PwC as well as Mrs Puma (the wife of Mr Puma) each hold 5%. d. Outsurance international (Pty) Ltd, an insurance company holds 5%. e. Mr Anderson holds 3% f. Apple (Pty) Ltd holds 30%, of which the shareholding in Apple (Pty) Ltd is held as follows: i. Mr Anderson holds 35% in Apple (Pty) Ltd ii. Mr McGregor holds 15% in Apple (Pty) Ltd iii. Mr Clayton holds 50% in Apple (Pty) Ltd g. Samsung (Pty) Ltd holds 25%, of which the shareholding in Samsung (Pty) Ltd is held as follows: 1. Mr Forbes holds 20% in Samsung (Pty) Ltd ii. Mrs PwC (Wife of Mr PwC) holds 50% in Samsung (Pty) Ltd iii. Mr KPMG holds 30% in Samsung (Pty) Ltd YOU ARE REQUIRED TO: Determine whether or not Cell Technologies (Pty) Ltd will be classified as a public or private company for tax purposes. (25 marks)