ABSTRACT
This chapter addresses the question: how can Asian-Pacific jurisdictions develop their trusts choice of law rules, in order to adapt to the future increase in cross-border trusts disputes? The chapter does not provide an absolute answer, but hopes to trigger a discussion on the matter by providing two tools which may help in the journey of developing trusts choice of law rules. First, it constructs a framework by which the development of trusts choice of law rules can be addressed across the region. Secondly, it demonstrates that a proper understanding of domestic substantive express, constructive, and resulting trusts is intricately related to the development of sound trusts choice of law rules.
Liew, Ying Khai, Trusts Choice of Law Rules in Asia-Pacific: Adapting to the Future (June 8, 2022). Hart Publishing, Forthcoming.
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