Abstract
Given its civil law tradition and, for over 70 years, rejection of the concept of private (as opposed to personal) property, the Russian Federation may seem an unlikely place for the concept of the trust to develop, but a trust-like phenomenon has been developed, and now forms part of the Russian Civil Code. In this article, the authors review these provisions, contrast the relationships for which they provide with a common law trust, note the very substantial similarities between them, and hazard a tentative view as to the possible application of the Hague Trusts Convention should the Russian arrangements come to be considered by a court in a Hague Convention jurisdiction.
€
David Russell and Karen Shakhnazarov, Russia—a new province for trust law?, Trusts and Trustees, Volume 23, Issue 9, 1 November 2017, Pages 936–943, https://doi.org/10.1093/tandt/ttx137.
First posted 2017-12-13 13:13:30
Leave a Reply