The paper estimates the share of FDI subject to additional tax following the implementation of BEPS Pillar Two. It first considers the scope of the new rules, where both the characteristics of the overall MNE group and its affiliates matter. There are two main findings: (i) large MNEs account for most foreign investment and (ii) low-tax affiliates often hold a disproportionate share of the FDI stock, even in countries where average or statutory tax rates are high. Around one-quarter of FDI is within the scope of the reform for the median country. Large MNE groups subject to Pillar Two explain around 70% of the FDI stock. Therein, 40% of investment is held by low-tax affiliates. Second, this paper develops a scenario for the initial implementation of Pillar Two. The rules take into account the undertaxed profits of all affiliates within an MNE group, including those abroad. Although limited in number, the countries first adopting reform are large global investors. Most of the affected FDI stock is located in offshore financial centers. However, the intersection of the reform’s scope and application implies a large share of the FDI stock in other countries will be subject to additional tax—around 15-20% in the typical case—with two-thirds located in developing countries.