28In section 213 (investment entity tax transparency election), after subsection (6) insert—
“(6A)Where, ignoring the election, profits and amounts of qualifying tax expense would be allocated to M in accordance with sections 168 and 178 to 181, those profits and amounts are to be allocated—
(a)first to M, and then
(b)to O in proportion to the direct ownership interests O is treated as having in M.”