Originating in common law, trusts were once completely foreign to continental European jurisdictions. This situation changed significantly when Liechtenstein enacted the Persons and Companies Act in 1926. It also continues to change as further jurisdictions undertake to recognise the trust. The increasing importance of – and demand for – trusts worldwide has led to increasing competition between jurisdictions. In order to remain competitive amongst other national legal systems, comparative analyses are becoming more important than ever.
This book presents a collection of essays, each providing an analysis of a trust law issue from at least one jurisdiction’s perspective. Following a chapter containing essays on general trust law issues, the essays in the second chapter focus on the extent to which trusts can be used for the purposes of asset protection – clearly presenting the different approaches taken. An analysis of beneficiaries’ rights under the laws of various jurisdictions is provided in the subsequent chapter’s essays, highlighting the fact that the treatment of beneficiaries also varies quite considerably. In the final chapter, the essays deal with international issues.