In the case where a foreign corporation having a permanent establishment receives the application of the provisions of Article 144-2-2, paragraph (1) (Credit for the Amount Equivalent to Foreign Tax Adjusted at the Time of Distribution for Foreign Corporations) with regard to the amount equivalent to foreign tax adjusted at the time of distribution prescribed in that paragraph pertaining to the amount of income tax on distributions of proceeds from a group investment trust that it receives, that amount equivalent to foreign tax adjusted at the time of distribution pertaining to the amount of income tax on the distributions of proceeds that it receives is excluded from deductible expenses, when calculating the amount of income pertaining to income attributable to a permanent establishment of the foreign corporation for each business year.