Conflict of Laws
Sometimes, in a civil law jurisdiction, a foreign trust is involved. This recognition often involved "translating" the trusts characteristics into legal figures that do exist within a country. With the accession of the United Kingdom to the European Community, the trust entered Community Law the law of the member state where the trust is constituted is designated as the applicable law (the law that must be followed) in member states. Certain trusts must be recognized by parties to the Hague Trust Convention (amongst which the civil law countries Italy, Liechtenstein, Luxembourg, the Netherlands and Switzerland) if they are following certain requirements: the trust must ben an express trust and documented in writing.
Read more about this topic: Trust Law In Civil Law Jurisdictions
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