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(4) For each chargeable period, for the purposes of computing the profits of a qualifying financing company chargeable to tax under Case III or IV of Schedule D in respect of each relevant loan, notwithstanding sections 70(3) and 76(5)(b), the company shall be entitled to deduct the amount of external interest paid by that company in that chargeable period as has arisen in relation to such portion of the external loan that is, in accordance with subsection (6), matched with that relevant loan.

(4) For each chargeable period, for the purposes of computing the profits of a qualifying financing company chargeable to tax under Case III or IV of Schedule D in respect of each relevant loan, notwithstanding sections 70(3) and 76(5)(b), the company shall be entitled to deduct the amount of external interest paid by that company in that chargeable period as has arisen in relation to such portion of the external loan that is, in accordance with subsection (6), matched with that relevant loan.

(8) No deduction shall be available under subsection (4) in respect of interest on any relevant loan unless, had the qualifying subsidiary or indirect qualifying subsidiary, as the case may be, borrowed the matched external loan, or portion thereof, as the case may be, directly, the qualifying subsidiary or indirect qualifying subsidiary, as the case may be, would be entitled to deduct interest on that loan under section 81, and where the qualifying subsidiary or indirect qualifying subsidiary, as the case may be, is not within the charge to tax in the State it would be, if it was so chargeable, entitled to such a deduction.

“control” shall be construed in accordance with section 432;

(ii) regarded as resident in a territory under arrangements having force of law by virtue of section 826(1) made with the government of that territory,