HARMONIZATION OF REGULATIONS IN THE AREA TRUST IN THE EUROPEAN-CONTINENTAL AND ANGLO-SAXON LEGAL SYSTEM

Abstract

In a world in which there is increasing globalization and the permeation of the institutions of once completely conflicting legal systems, the harmonization of legal rules and practices is necessary. This process has not bypassed the European Union either, where it has been particularly intense since the eighties of the last century. However, this interweaving not only leads to the appearance of the same solutions in once different legal systems, but also very often affects the fundamental principles of each individual legal system. A good example of this is the English institute of trust, which owes its origin and development entirely to the Anglo-Saxon legal spirit, and which appears more and more often in the practice of European-continental courts. In the paper, the author gives a brief overview and analysis of the most important conventions and documents by which international actors tried to standardize the rules regarding the recognition and application of trusts, and based on this, she will try to predict the further fate of trusts in Euro-continental law.