Trust Law in Asian Civil Law Jurisdictions: A Comparative Analysis

The reception of the trust in civil law jurisdictions has generated considerable conceptual debate internationally and in East Asia. In Trust Law in Asian Civil Law Jurisdictions, the authors: • Provide a detailed comparative examination of trust laws in Asian civil law jurisdictions from both operational and theoretical perspectives • Discuss the reception of the trust laws in Japan, South Korea, Taiwan and China and the challenges facing them • Engage in in-depth comparative inquiries as to how these Asian legal systems resolve questions pertaining to the trust • Evaluate the distinctive features of Asian trusts and how they are moulded to suit the civilian legal frameworks within which they are situated. The analysis intersects with the Trento trust project in Europe, but also differs from it by providing valuable perspectives of the 'Asian' approaches to trust researchers in Asia and the Anglophone world at large.

• Helps researchers and practitioners to understand the historical background of and latest developments in trust laws in civil law jurisdictions in East Asia

• Use of Trento trust project scenarios allows readers to draw close comparisons within these Asian jurisdictions and between them and the European jurisdictions considered in the Trento project

• Provides readers with a deep understanding of the theoretical issues arising from the reception of the trust in Asia and a critical evaluation of Asian approaches