(1) In this section -
'foreign loss' means a loss or other amount eligible for group relief in accordance with section 411(2A);
'relevant foreign loss' means the amount of a foreign loss that -
(a) corresponds to an amount of a kind that, for the purposes of section 420 or 420A, could be available for surrender by means of group relief by a company resident in the State,
(b) is calculated in accordance with the applicable rules under the law of the surrendering state for determining the amount of loss or other amount eligible for relief from tax in that state,
(c) is not attributable to a trade carried on in the State through a branch or agency,
(d) is not otherwise available for surrender, relief or offset in accordance with any provisions of the Tax Acts,
(e) is a trapped loss within the meaning of subsection (2), and
(f) is not available for surrender, relief or offset under the law of any relevant Member State, other than the State or the surrendering state;
'surrendering state' me
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