The main focus of this study is to deal with the tax treatment of CISs and trusts under DTCs “de lege lata”. A symmetrical structure was fol-lowed in the analysis of hybrid entities such as CISs and trusts. Interest-ingly, however, the practical proposals to amend the OECD Model and OECD Commentary presented in this study are mainly asymmetrical. This study aims at examining whether CISs and trusts can request and be entitled to the application of DTCs.weiterlesen