Orbit Corporation (Orbit), is a U.S. corporation, has established in Country C a branch office that coordinates the export sales throughout Africa of Orbit products manufactured by Orbit in the United States. Since the office is not actually engaged in the sales transactions, which are handled by Orbits export division in New York, no revenue appears on the books of the Country C branch; only the expenses of the office are reflected on its books. Country C has a generally applicable income tax. Recognizing, however, the difficulty of determining the proper amount of the net export income attributable to the Country C branch office, the Country C tax authorities issue a ruling to the effect that the branch will be taxed on the assumption that the gross income of the office will equal 120% of the expenses of the office. This assumed income less the actual expenses of the office will be subject to the generally applicable Country C income tax of 35%. Will the resulting Country C tax will be creditable?