ABSTRACT
This chapter will concentrate on the issues of applicable law and jurisdiction ((i) and (ii) above) and a provisional assessment will be made of the extent to which such rules have led to increased recognition of cross-border trusts in the Asia-Pacific region. In wholly domestic cases differences between national laws on trusts, torts or contracts are normally only a matter of comparative curiosity but if a transaction crosses national boundaries, then the differing legal conceptions can come into conflict.
Garnett, Richard, Identifying an Asia-Pacific Private International Law of Trusts (2021) in Y Liew and M Harding (eds), Asia-Pacific Trusts Law: Theory and Practice in Context (2021) Hart Publishing 381-404.
First posted 2022-01-18 08:00:30
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