(1) In this section -
‘arrangements’, other than in paragraph (b)(ii) of the definition in this subsection of ‘qualifying subsidiary’, includes any agreement, understanding, scheme, transaction or series of transactions (whether enforceable or not);
'associated enterprise', in respect of a company, means an enterprise that is an associated enterprise of that company for the purposes of Chapter 4 of Part 35C;
'control' shall be construed in accordance with section 432;
'EEA state' means a state, not being a Member State or the State, which is a contracting party to the Agreement on the European Economic Area signed at Oporto on 2 May 1992 as adjusted by the Protocol signed at Brussels on 17 March 1993;
'enterprise' has the same meaning as in Part 35C;
'external interest' means the amount of interest payable on an external loan;
'external loan', subject to subsection (11), in respect of a company, means a loan from a person who -
(a) does not have the beneficial ownership of, or
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