The presentation will begin by reviewing the taxation regime for the principal instruments of implementing ESOPs based on the modification of the published practice. This overview will come back on notions such as qualification of ESOP for type of participation in a company or the relation of the employee with the employer, the tax consequences at exercise, grant and sale. The presentation will then focus on some current practical topics which are being discussed between tax advisors and tax authorities, such as the qualification of a “start-up” for wealth tax purposes or the impact of financing rounds or sweet equity when it comes to using loans in ESOPs. Those specific topics will be illustrated through concrete examples from the practice.