Trust law in Civil law jurisdictions

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Trust law in civil law jurisdictions

Most jurisdictions that have the trust concept do so because their legal systems are based on the English legal system, (a common law system), where the trust was developed. As such, trusts tend to be most prevalent in Commonwealth jurisdictions.

However, at least two jurisdictions, Switzerland and Liechtenstein, are civil law jurisdictions which have "imported" the trust concept into their laws by means of statute. The basic principles of trust law in those jurisdictions are very much as set out in this article, with some variations, but the legal and intellectual underpinning of that law is entirely different.

The private foundation, if founded in a civil law jurisdiction, may be seen as a civil law equivalent of the common law trust.