JFrog Ltd Income Taxes Disclosure

14. Income Taxes

Ordinary taxable income in Israel is subject to a corporate tax rate of 23%.

The Company applies various benefits allotted to it under the revised Investment Law as per Amendment 73, which includes a number of changes to the Investment Law regimes through regulations that have come into effect from January 1, 2017. Applicable benefits under the new regime include:

The Company adopted the PTE status since 2017 and believes it is eligible for its tax benefits.

The Company may also receive benefits pursuant to the Law for the Encouragement of Knowledge Intensive Industry (Temporary Provision), 2023 (the “Angel’s Law”), which was enacted on July 31, 2023. The Angel’s Law provides certain benefits to entities that qualify as PTE, including special deductions in connection with acquisitions where certain criteria are met.

The Company’s subsidiaries are separately taxed under the domestic tax laws of the jurisdiction of incorporation of each entity.

Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes.

A valuation allowance is provided when it is more likely than not that the deferred tax assets will not be realized. The Company has established a valuation allowance to offset certain deferred tax assets as of December 31, 2025 and 2024 due to the uncertainty

of realizing future tax benefits from its net operating loss carryforwards and other deferred tax assets. The net change in the total valuation allowance for the years ended December 31, 2025, 2024, and 2023 was an increase of $12.2 million, $5.8 million and $8.9 million, respectively. For the year ended December 31, 2024, the Company recognized a discrete tax benefit of $4.4 million in Israel attributable to the release of valuation allowance as a result of recognizing deferred tax liabilities associated with the Qwak acquisition.

As of December 31, 2025, the Company had $239.7 million in net operating loss carryforwards in Israel, which can be carried forward indefinitely.

As of December 31, 2025, the U.S. subsidiary had state net operating loss carryforwards of $76.5 million available to offset future taxable income, which will expire between 2034 and 2044, if not utilized. The U.S. subsidiary had an immaterial federal net operating loss carryforward as of December 31, 2025.

As of December 31, 2025, certain foreign subsidiaries of the Company had undistributed earnings of $25.9 million, which were designated as indefinitely reinvested. If these earnings were repatriated to Israel, it would be subject to income taxes and to an adjustment for foreign tax credits and foreign withholding taxes. The Company has estimated the amount of unrecognized deferred tax liability related to these earnings to be approximately $2.0 million.

Cash paid for income taxes, net of refunds was as follows:

As of December 31, 2025, the total amount of gross unrecognized tax benefits was $7.6 million, of which, $4.1 million, if recognized, would favorably affect the Company’s effective tax rate.

The Company recognizes interest and penalties related to uncertain tax positions in income tax expense. As of December 31, 2025 and 2024, accrued interest and penalties related to uncertain tax positions were immaterial.

The Company has net operating losses from prior tax periods which may be subjected to examination in future periods. As of December 31, 2025, the Company’s tax years after 2020 are open to examination in Israel. Its U.S. subsidiary’s tax filings for tax

years after 2021 are open to examinations by U.S. federal tax authorities and tax years after 2022 are open to examinations by U.S. state tax authorities. In addition, the U.S. federal tax returns were settled through 2018 except for any adjustments which might be made as a result of the carryback of net operating losses. As of December 31, 2025, the Company’s subsidiary in France is under examination by the local tax authorities for the 2023 tax year. The Company does not expect the results of the examination to have a material impact on its consolidated financial statements. The Company currently does not expect uncertain tax positions to change significantly over the next 12 months, except in the case of settlements with tax authorities, the likelihood and timing of which is difficult to estimate.

On July 4, 2025, the “One Big Beautiful Bill Act” (“OBBBA”) was enacted into law. The OBBBA includes significant changes to the U.S. tax law, including the extension and modification of several key provisions of the Tax Cuts & Jobs Act. For the year ended December 31, 2025, OBBBA did not have a material impact on the Company’s consolidated financial statements. In addition, the Company does not expect the provisions of the OBBBA that become effective in future years to have a material impact on its consolidated financial statements.