Abstract
Abstract England is the cradle of trusts and China introduced this flexible institution for its own needs and promulgated its trust law in 2001. Different to England, China does not have unified fiduciary doctrines and the Chinese trust has a strong contractarian nature. This article compares Chinese law and English law in terms of the rules about trustees’ duties of loyalty. The apparent differences reflected on micro rules may find their explanation in the macro trust structures and legislative backgrounds.
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