[414 Qualifying net group-interest expense]

[414  Qualifying net group-interest expense]

[(1)     For the purposes of this Part the “qualifying net group-interest expense” of a worldwide group for a period of account of the group is (subject to subsection (2))—

A - B

where

A is the adjusted net group-interest expense of the group for the period (see section 413);

B is the sum of any downward adjustments (see subsection (3)).

(2)     Where the amount determined under subsection

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