Recognition of a foreign trust as a problem of private international law

Abstract

The contribution deals with the terms under which the trust can function in foreign legal order. This presupposes its recognition which is a method used rather in case of foreign court decisions.

Recognition means a transposition of the trust into new legal context in order to fulfill its functions like in the mother legal order. To achieve this aim it is necessary that the trust should be adapted in order to work like the most similar legal institutes.

Keywords

• Trust, recognition
• functioning
• foreign legal order
• adaptation