ABSTRACT
The following paper is a brief overview of how trusts and trust-like arrangements work in four selected civil-law jurisdictions, including a regional jurisdiction (Quebec). The influence of the 1985 Hague Convention and of relatively recent EU law on the matter is also reported.
In light of its brevity, this paper is to circulate only privately, but it may eventually become part of a larger summary on the issue of a doctrinal adoption of trusts into a civil-law systems, taking into account not only dogmatic hurdles but also potential economic considerations.
Martin M, Civil Law Trusts? Lessons from Quebec and other jurisdictions (December 18, 2022).
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