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UAE Unincorporated Partnerships and Pillar Two: can a partnership interest fit the Ownership Interest, Controlling Interest and UPE chain?

Even where a UAE Unincorporated Partnership can qualify as an Entity, and even where it can in some cases matter within the Group perimeter, the analysis does not stop there. The GloBE Rules also rely on a chain of owner-ship-and-control concepts (Ownership Interest, Controlling Interest, and Ul-timate Parent Entity) in order to identify the upper structure of the group. The question is whether a partnership interest can fit naturally within that chain, or whether the language of the Model Rules points more strongly toward equity-type interests in the corporate sense.
Part One addressed the threshold question whether a UAE Unincorporated Partnership can qualify as an Entity for Pillar Two purposes. Part Two then turned to the next step, namely whether being an Entity is enough, or whether the arrangement must also enter the Group architecture through the relevant consolidated financial statements. The analysis there showed that the answer may depend heavily on whether the arrangement is reflected line by line, proportionately, or only through the equity method.
The present article (Part Three) turns to the third question: if a UAE Unin-corporated Partnership can be an Entity, and if it can in some cases matter within the Group perimeter, can a partnership interest fit the chain of con-cepts that runs from Ownership Interest to Controlling Interest and ultimately to Ultimate Parent Entity?