Comparison between “Trusts” under Common Law and Civil Law
Is there something like a “Common Law Trust” in the Civil Law System?
Probably not, because trusts are developed in the middles ages at the time of the Crusaders and are a product of the different court systems of law and equity in England. However, the Civil Law System has its own “trust product”: Foundations, and to some degree Liechtenstein Establishments. What are the characteristics of a Foundation and Establishment, how are they formed and what are the main differences from a Common Law Trust?
For further information: My presentation at the Israeli Bar Association, April 19, 2021>
