A partnership interest has no votes to measure, so the Competition Act measures something else entirely.
Short answer
No — different mechanics entirely. Section 110(6) of the Competition Act applies its own conjunctive test to an acquisition of an interest in a non-corporate combination such as a partnership: a dollar-value test under s.110(6)(a), plus a percentage test under s.110(6)(b) measured on entitlement to profits or to assets on dissolution — 35%, or 50% if the acquirer is already past 35% — not on votes, because a partnership interest carries no votes to measure.
Section 110(6)(b) sets the threshold: notification applies “if, as a result of the proposed acquisition of the interest, the person or persons acquiring the interest, together with their affiliates, would hold an aggregate interest in the combination that entitles the person or persons to receive more than 35% of the profits of the combination, or more than 35% of its assets on dissolution, or, if the person or persons acquiring the interest are already so entitled, to receive more than 50% of such profits or assets.” Reaching for the familiar 20%/35%/50% voting-share tiers from s.110(3) on a deal with no shares and no votes is the mistake this provision is built to catch.
A different provision applies when two or more people are forming the combination itself, rather than one acquiring an interest in an existing one. Section 110(5) reads: “this Part applies in respect of a proposed combination of two or more persons to carry on business otherwise than through a corporation if one or more of those persons … proposes to contribute to the combination assets that form all or part of an operating business,” tested only against the dollar-value figures in s.110(7)/(8) — no percentage test at all. Section 114(1)(c) is what actually requires notification once that threshold is crossed: “two or more persons propose to form a combination in the circumstances set out in subsection 110(5).”
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