Article 7 provides specific rules for groups with flow-through entities, deductible dividend regimes, and investment entities. It outlines how a UPE that is a flow-through entity can reduce its Pillar Two Income based on the tax status of its owners. The article introduces the Investment Entity Tax Transparency Election and the Taxable Distribution Method, allowing groups to manage the tax treatment of investment vehicles. It also details the Equity Investment Inclusion Election and the treatment of Qualified Flow-through Tax Benefits, ensuring that tax neutrality and distribution-based tax systems are properly integrated into the GloBE framework.