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Trust law in civil law jurisdictions
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). Trust law enters civilian jurisdictions through conflict of law arrangements recognizing it as a matter of private international law and has been implemented in the civil code of certain countries such as Liechtenstein and Curaçao.
==Conflict of laws==
Sometimes, in a civil law jurisdiction, a foreign trust is involved. This recognition often involves "translating" the trust's characteristics into legal concepts that do exist within the civil law 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 (the ''situs'') 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 be an express trust reduced to writing.〔(【引用サイトリンク】title=Status Table: 30: Convention of 1 July 1985 on the Law Applicable to Trusts and on their Recognition )〕
抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』
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