The fiduciary relationship and the fiduciary duty by (not only) foreign jurisdictions

Abstract

The terms of "fiduciary relationship" and "fiduciary duties" are ambiguous. Their understanding is different across legal jurisdiction.

While the concept of fiduciary relations is typical for the Anglo-American doctrine, the Czechs and Germans do not use the same terminology. However, this does not mean that the functional equivalents of the fiduciary relationship (and obligations relating to them) are entirely unknow in the Czech and German jurisdictions.

Keywords

• fiduciary relationship
• fiduciary duty
• loyalty
• care