Abstract

While the common law trust (or fiscal benefits derived from it) is under sustained attack in the jurisdiction of its birth, in the emerging international financial centres the need for and encouragement of the use of trusts is growing apace. Perhaps the most ambitious and comprehensive effort to transplant the trust concept into new ground is that in progress in the Dubai International Financial Centre. That effort is being pursued using a combination of sources, some of which are novel and some already well-tried. Some comparisons with Bahrain's 2006 trust law help to illustrate this point.

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