The Revenue have published an eBrief on S.79B TCA 1997.

Section 79B Taxes Consolidation Act 1997 – Matching of foreign currency assets with certain foreign currency share capital, was introduced by Finance Act 2006. The provision was introduced to allow for all companies the matching of a foreign currency asset with redeemable share capital denominated in the same currency.

The purpose of the eBrief is to deal with circumstances where the legislation does not provide for the tax neutrality which had been intended. According to the eBrief, the Minister for Finance intends to bring forward a number of legislative amendments in the Finance Bill 2007 to ensure that the provision operates as originally intended.

Revenue eBrief No. 47/2006 has been reproduced at Section 2.03.