Is the head trust an Active NFE?

I have been researching on CRS implication on trusts, and one of the questions has been pending in my mind for a clear answer.

At the top of the figure, according Section VIII (D)(9)(d) of CRS and its commentary, the trust as an Entity defined in CRS can be considered as an Active NFE so long as the underlying subsidiaries all engaged in trading and manufacturing business without passive income.

But there is little discussion on this and most simply think that all family trusts are passive NFE.

What is your take on this?

Jason Tian
Shanghai Landing Law Office