"Chapter 8 considers the application of tax treaties based on the OECD Model to trust-related income. Particular emphasis is placed on the transparent entity clause and saving clause proposed by the BEPS project and now incorporated into the OECD Model and how they apply to trust income, having regard to differential transparency and the possibility of grantor attribution. It considers the availability and extent of treaty benefits in trust situations and proposes a number of drafting strategies, including a proposal to address otherwise unrelieved double taxation where two countries each attribute the same income to their own resident. Consideration is also given to the interaction between tax treaties and national taxation of trust income and, separately, of trust distributions."