(1) This section shall apply to a relevant entity for an accounting period where -
(a) the relevant entity is not, at any time in that accounting period, a standalone entity,
(b) the relevant entity has a disallowable amount greater than zero in respect of the accounting period, and
(c) the exceeding borrowing costs of the relevant entity exceeds the de minimis amount.
(2) For the purposes of determining whether the exceeding borrowing costs of a relevant entity exceeds the de minimis amount for an accounting period -
(a) in a case in which an amount of deductible interest equivalent is deducted against profits chargeable to tax at the P rate, the amount of that deductible interest equivalent shall be adjusted as follows:
where -
IEded-adj is the adjusted amount of deductible interest equivalent in respect of the relevant entity for the accounting period, and
IEded is the amount of deductible interest equivalent in respect of the relevant entity for the accounting period deducted agai
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