The Israeli Tax Authority’s new Position Paper (1/2025) clarifies that ESOPs may still qualify for favorable 25%-30% capital gains tax treatment during M&A exits or IPOs, even when vesting is accelerated — a shift from prior uncertainty. However, the conditions under Section 102, including trustee holding periods and prior approval, must still be met, and complexities remain, especially regarding the start of vesting and single vs. double trigger acceleration. Despite the tax benefits now being more accessible, the rules are intricate and may require companies to seek formal tax rulings during exits to ensure compliance and minimize risk.