Group Own funds

On group template S.23.01, most basic own funds items are subdivised into two parts: a main part and the non-available part at group level. For instance minority interests (R0200) and non-available minority interests at group level (R0210). For each of theses cases, should the non-available part be included in the main item on the row above?

We are asking for clarification purposes, as template instructions do not specify if the non-available at group level part for relevant items should be included in the main part, but guidelines set in article 222 of directive 2009/138 consider these part of the related undertaking's SCR, and they should not appear in the group SCR. Following this approach, this means that R0020, R0060, R0080, R0100, R0120, R0150, R0170, R0190 and R0210 should not be included in their respective above items. However since they are included in deductions (as the total of non-available own fund items in R0270), by doing so they would actually be deducted twice: the total basic own funds after deductions on R0290 would not include them in the first place (because the according sums are not reported on R0010, R0050, R0070, R0090, R0110, R0140, R0160, R0180 and R0200), then substract them as deductions from R0280.