Legal transplants are considered a significant factor in the evolution of legal systems. One example of transplant of a legal institution through its prestige is the diffusion of the trust from the English legal system to other common law systems and to many civil law countries. One of these is China that in 2001 enacted the Trust Law of the People's Republic of China. This paper wants to analyse the trust under the Trust Law and to compare it with the original model in the English legal system, understanding how far or how close it is from the original one.
The Transplant of Trusts in Different Legal Jurisdictions: The Example of China / G. Terranova. - In: GLOBAL JURIST. - ISSN 1934-2640. - 20:3(2020 Oct), pp. 20190060.1-20190060.12. [10.1515/gj-2019-0060]
The Transplant of Trusts in Different Legal Jurisdictions: The Example of China
G. Terranova
2020
Abstract
Legal transplants are considered a significant factor in the evolution of legal systems. One example of transplant of a legal institution through its prestige is the diffusion of the trust from the English legal system to other common law systems and to many civil law countries. One of these is China that in 2001 enacted the Trust Law of the People's Republic of China. This paper wants to analyse the trust under the Trust Law and to compare it with the original model in the English legal system, understanding how far or how close it is from the original one.
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