English to Russian Law/Patents Law: Taxation & Customs

подскажите, пожалуйста, это о части налога, доходе или вычете, т.е. "который" или "которая"? и как лучше перевести attributable?

The deduction provided for in paragraph 2 need not exceed the lower of:
(b) that part of the tax on the income of the company or permanent establishment which received the interest or royalties, as computed before the deduction is given, which is attributable to those payments under the domestic law of the Member State of which it is a company or in which the permanent establishment is situated.