<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
                                                            March 10, 2025

Jonathan Alexander Assia
Chief Executive Officer
eToro Group Ltd.
30 Sheshet Hayamim St.,
Bnei Brak, Israel 5120261

       Re: eToro Group Ltd.
           Amendment No. 4 to Draft Registration Statement on Form F-1
           Submitted March 3, 2025
           CIK No. 0001493318
Dear Jonathan Alexander Assia:

     We have reviewed your amended draft registration statement and have the
following
comments.

       Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our January 10, 2025 letter.

Amendment No. 4 to Draft Registration Statement on Form F-1
Market, Industry and Other Data
Testimonials, page 3

1.     Please ensure that the testimonials provided throughout the prospectus
are not so
       extensive that they obscure other prospectus disclosure. In addition,
please confirm
       that you have received consents to the inclusion of the quotes in the
prospectus from
       the relevant individuals. Please also disclose whether any of these
individuals were
       compensated for their testimonials.
 March 10, 2025
Page 2
Index to Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 2 - Significant Accounting Policies, page F-9

2.     Please revise your next amendment to provide additional information
regarding your
       $65 million short-term investment, including the nature of the
investment, terms, and
       your accounting policy.
U. Financial Instruments
(4) Hedge accounting, page F-23

3.     Please revise your policy to clarify how you account for the fair value
hedges related
       to your employee investment plan as disclosed in the last paragraph of
the footnote.
Note 17 - Taxes on Income
D. Pillar Two, page F-45

4.     Please tell us, and revise your disclosure accordingly, why you do not
expect to be
       within the scope of Pillar Two at December 31, 2024 when you also
disclose that
       multinational enterprises with global revenues of at least    750
million in at least two
       of the previous four years are in the scope of Pillar Two. In this
regard, it appears that
       you have revenues in excess of    750 million in each of the last three
years.
F. Taxes on Income Included in Profit or Loss, page F-46

5.     We note that $12,995,000 of your $53,238,000 income tax provision in
2024 is related
       to prior years. Please tell us why this provision, representing 24.4% of
your total
       provision and 5.3 percentage points of your total 21.7% effective tax
rate, is properly
       recorded in 2024. In your response specifically tell us why this
provision was not
       recorded in 2023 or an earlier period. Reference for us the
authoritative literature
       you relied upon to support your accounting.

       Please contact David Irving at 202-551-3321 or Mark Brunhofer at
202-551-3638 if
you have questions regarding comments on the financial statements and related
matters. Please contact Irene Paik at 202-551-6553 or Sandra Hunter Berkheimer
at 202-551-
3758 with any other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Crypto
Assets
cc:   David J. Goldschmidt
</TEXT>
</DOCUMENT>
