Ireland and Apple are close to a deal to protect the Irish government from any losses that could occur while it holds as much as 15bn euros (£136bn) of the iPhone maker’s money during a tax fight with European Union regulators, according to two people familiar with the matter.

In an order that reverberated across the Atlantic, the European Commission last year slapped Apple with a multibillion-euro bill, saying Ireland granted unfair deals that reduced the company’s effective corporate tax rate.

Irish authorities will place the money in an escrow account pending an appeal.

If the appeal, which could take as long as five years, is successful, the money will be returned to Apple. Ireland wants to make sure it isn’t liable for any drop in the value of the fund while the case winds its way through the EU courts.

An agreement on the issue may come within weeks, said one of the people, who spoke on condition of anonymity because the negotiations on the structure of the proposed account have yet to be finalised.

“We continue to cooperate with Ireland on the recovery process the commission has mandated but remain confident that once the General Court of the EU has reviewed all the evidence it will overturn the commission’s decision,” Apple said, while declining to comment on the funds.

Ireland should step up its efforts to recoup about unpaid taxes from Apple or it could end up in court, the EC said in May. The money was supposed to be collected by January.

The terms of the fund are still being negotiated, the government said last month, as it sought tenders to manage the money.

Including interest, the figure may reach 15bn euros, the government said last month.

The Irish debt office, which will help oversee the money on behalf of the government, declined to comment. The European Commission said it expects that Ireland will make material progress to implement recovery “as soon as possible.”