Trust law and Trust law in civil law jurisdictions

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Difference between Trust law and Trust law in civil law jurisdictions

Trust law vs. Trust law in civil law jurisdictions

A trust is a three-party fiduciary relationship in which the first party, the trustor or settlor, transfers ("settles") a property (often but not necessarily a sum of money) upon the second party (the trustee) for the benefit of the third party, the beneficiary. Trust law is not part of most civil law jurisdictions, but is a common figure in most common law system (and thus in most Commonwealth jurisdictions).

Act (document)

An act is an instrument that records a fact or something that has been said, done, or agreed.

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Civil code

A civil code is a systematic collection of laws designed to deal with the core areas of private law such as for dealing with business and negligence lawsuits and practices.

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Civil law (legal system)

Civil law, civilian law, or Roman law is a legal system originating in Europe, intellectualized within the framework of Roman law, the main feature of which is that its core principles are codified into a referable system which serves as the primary source of law.

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Common law

Common law (also known as judicial precedent or judge-made law, or case law) is that body of law derived from judicial decisions of courts and similar tribunals.

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Conflict of laws

Conflict of laws concerns relations across different legal jurisdictions between natural persons, companies, corporations and other legal entities, their legal obligations and the appropriate forum and procedure for resolving disputes between them.

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Curaçao

Curaçao (Curaçao,; Kòrsou) is a Lesser Antilles island in the southern Caribbean Sea and the Dutch Caribbean region, about north of the Venezuelan coast.

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Express trust

An express trust is a trust created "in express terms, and usually in writing, as distinguished from one inferred by the law from the conduct or dealings of the parties." Property is transferred by a person (called a trustor, settlor, or grantor) to a transferee (called the trustee), who holds the property for the benefit of one or more persons, called beneficiaries.

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Hague Trust Convention

The Hague Convention on the Law Applicable to Trusts and on their Recognition, or Hague Trust Convention is a multilateral treaty developed by the Hague Conference on Private International Law on the Law Applicable to Trusts.

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