772.5.6. For the purposes of this chapter, a taxpayer who is resident in Canada throughout a taxation year and carries on a foreign oil and gas business in a taxing country in the year is deemed to have paid in the year as an income or profits tax to the government of the taxing country an amount equal to the lesser of(a) the amount by which 40% of the taxpayer’s income from the business in the taxing country for the year exceeds the total of all amounts that are, but for this section, income or profits taxes paid in the year in respect of the business to the government of the taxing country; and
(b) the taxpayer’s production tax amount for the business in the taxing country for the year.