委托人设立保留信托财产的管理、处分或收益控制权的他益信托,达到规避信托收益所得税的目的。委托人信托的真实受益人并非信托关系中的名义受益人,而是委托人自己。应根据实质课税原则,否认委托人信托的避税效果。英国、美国、日本等信托税制发达的国家,在所得税法中确立了委托人纳税的规则。我国应借鉴国外成功的立法经验,建立防止委托人信托避税的法律制度。 The trustor sets up his own trust that reserves the trust property management, disposition or gain control, thus avoiding the income tax on trust income. The true beneficiary of the principal trust is not the nominal beneficiary of the trust, but the principal. Should be based on the principle of substantive taxation, deny the client’s trust tax avoidance effect. Countries with developed trust tax systems such as the United Kingdom, the United States, and Japan established the principle that taxpayers pay taxes in the Income Tax Law. Our country should draw on the successful experience of legislation in other countries and establish a legal system to prevent the client’s trust from tax avoidance.