A magyar bizalmi vagyonkezelés egyes külföldi országok szabályozásainak tükrében

Abstract

At the end of the 20th century, several Eastern European countries showed strong interest in the Anglo–Saxon institution of the trust. The main reason for this is attributable to the advantages of the trust offered for the economy. Legislators in some Eastern European countries tried to cope with problems relating to the adoption of a trust-like legal institution. As the result of their efforts, the civil code of Russia (1995/96), Lithuania (1996/2000), Georgia (2002), Romania (2011), the Czech Republic (2012) and Hungary contains regulations that resemble the trust. These laws vary significantly because the Georgian model remains on a contractual level along with the Russian law. In Lithuania it is possible to establish a so-called right of trust, which is an independent item in rem right. The Romanian regulation is very similar to the French fiducie, while the Czech trust law was worked out on the basis of the Quebec model. The Hungarian regulation was drawn up on the basis of the model of the trust in English law and that of the Treuhand in German law.