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(a) interest is payable by a person, directly or indirectly, to a connected person (being interest which, if it were paid, would be chargeable to tax under Schedule D),

A is the aggregate of amounts of interest on the relevant liability which are chargeable to tax as income of the connected person, or would be so chargeable but for the provisions of section 198 or of arrangements having the force of law by virtue of section 826 826(1)(a), 826(1), for all chargeable periods the basis periods for which end on or before the relevant date in relation to the first-mentioned chargeable period, and

(i) “control” shall be construed in accordance with subsections (2) to (6) of section 432 as if in subsection (6) of that section for “5 or fewer participators” there were substituted “persons resident in the State”, and

“chargeable period” and “basis period” have the same meanings as they have for the purposes of section 817B;

A is the aggregate of amounts of interest on the relevant liability which are chargeable to tax as income of the connected person, or would be so chargeable but for the provisions of section 198 or of arrangements having the force of law by virtue of section 826 826(1)(a), 826(1), for all chargeable periods the basis periods for which end on or before the relevant date in relation to the first-mentioned chargeable period, and