In 2022-23, the Model Rules of Pillar Two have been approved by the OECD and at EU level through a Directive, introducing a 15% global minimum tax (GMT). Pillar Two is now fully operative and binding in the EU. Who bears the costs? Who gets the benefits? A first assessment, with Reuven Avi-Yonah, Ana Cinta González Cabral, and Carlo Garbarino.