Although an entity is not identified as a "trust" in its country of establishment, it could fall within the scope of the filing duty in France in relation to trusts as long as it meets the French Tax Code (hereinafter "FTC") definition of a trust, i.e. the legal relationship created in a foreign State by a settlor – during his lifetime or on death – seeking to put under control of a trustee (or "administrator") assets or rights in the interests of either one – or more – beneficiaries or one special purpose[1].