For the purposes of
section 157, if the trustee of a discretionary trust is a linked entity,
a potential beneficiary under the trust is taken to have —
(a) a
100% interest in the trust; or
(b) if
the Commissioner decides in a particular case that the operation of
paragraph (a) would be inequitable, either —
(i)
an interest in the trust of some other percentage; or
(ii)
no interest in the trust,
as determined by the
Commissioner.