Abstract
Abstract The current Civil Code of Romania took inspiration from the Civil Code of Quebec in lifting the prohibition on fideicommissary substitutions. In doing so, it also made explicit reference to fiduciary duties when regulating the obligations incumbent on the first beneficiary. This particular provision divided the local literature with some authors embracing the transplant and others criticizing it. Our article argues that the fideicommissary substitution and the fiducia are essentially two sides of the same coin, with said transplant being a welcome development in the Romanian law of succession.
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