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Trusts in Civil Law and Common Law Jurisdictions

This paper is a discussion of the law of trusts as it is found in civil law and common law jurisdictions, noting how the trust developed in British common law and has since been adapted in many countries based on civil law, based on different origins as common law traditions derive from English law, while civil law derives more from Roman law, with the two melding over time.

  • Pages: 21
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  • Filename: 21150
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