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The trust originates from the Anglo-Saxon legal tradition and has been a consolidated concept there for centuries. For a long time, however, it was considered incompatible with the legal systems of civil
law due to incompatibility with its fundamental principles. Despite continuing reservations, various civil law jurisdictions have since adopted the trust or codified new institutions modeled on it. The "Hague Convention on the Law Applicable to Trusts and their Recognition" ("HTrÜ") was the impetus for this development. Italy was the first country with a civil law legal system to establish its obligation to "recognize" the trust. Thus, the accession to the HTrÜ raised difficult questions of "whether", "how" and "to what extent" a trust should be recognized. Using Italy as an example, Leonie Neu shows that the trust is not a compulsory instrument.
Language | German |
Item number | 7852416 |
Publisher | |
Category | |
Release date | 4/30/2018 |
Language | German |
Year | 2018 |
Number of pages | 384 |
Book cover | Paperback |
Specifications may include unverified machine translations.
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