(1) Section 12A (inserted by the Finance Act, 1994) of the Corporation Tax Act, 1976, is hereby amended -
(a) in subsection (1)(a) by the insertion after the definition of "relevant contract" of the following definition:
"‘relevant tax contract’, in relation to an accounting period of a company, means any contract entered into by the company for the purpose of eliminating or reducing the risk of loss being incurred by the company due to a change in the value of money payable in discharge of a liability of the company to corporation tax for the accounting period being a change resulting directly from a change in a rate of exchange of the functional currency (within the meaning of section 14A) of the company for the currency of the State;", and
(b) by the addition after subsection (3) of the following subsection:
"(4) Notwithstanding section 13, so much of the amount of any gain or loss arising to a company which carries on a trade in the State in an accounting period as -
(a) i