EL TRUST EN EL DERECHO SUCESORIO ESPAÑOL.

Abstract

The concept of trust has been put into practice in the Common Law countries and more and more this type of instrument is being utilized. However, in Spain trusts are not regulated in the Spanish conflict of laws. There is a wide variety of trusts: inter vivos trusts and mortis causa trusts. This work refers to mortis causa trusts. The question ist which Spanish conflict rule and material rules are applicable by Spanish judge to resolve a case law about a foreign trust.