Dr. Avi Nov Adv.
The grant of Restricted Stock Units (RSU) is not clearly regulated by the Israeli Income Tax Ordinance [New Version] 1961 (the "Ordinance"), as other forms of employees stock options regulated under section 102.
For more details see:
Israeli Tax Authority decision
The Israeli Tax Authority issued a decision (Decision 139/06), in which the Israeli Tax Authority permitted RSU to be considered as options regulated under section 102 in the “capital gains route”.
That is to say that the gains derived from the RSU shall be subject to capital gains tax (25%), provided that the trustee held the RSU for at least 24 months. The ruling is contingent upon compliance with the other conditions stipulated in the Ordinance and in that ruling.