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“Dual Ownership” Versus “Absolute Ownership”: A Comparative Analysis

In: Ownership of Trust Property in China

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  • Zhen Meng

    (Nanjing University of Science and Technology)

Abstract

This Chapter provides a comparative analysis on the diverse approaches in which the civil law countries deal with the issue regarding the ownership of trust property. The basic concepts of the “dual ownership” and “absolute ownership”, and the conflict between these two concepts are elaborated in the first section of this Chapter. Then, this Chapter outlines the different scenarios regarding the ownership of trust property in China. Specifically, it examines various conventional interpretations of Article 2 of the Chinese Trust Law suggested by Chinese legal scholars. Further, this Chapter moves on to explain the approaches adopted by the so-called “mixed jurisdictions” such as Scotland, Quebec, Louisiana, and South Africa; also, the trust laws in East Asian jurisdictions such as Japan, Korea, and Taiwan are overviewed. This Chapter ends with a critical summary of the existing debates.

Suggested Citation

  • Zhen Meng, 2017. "“Dual Ownership” Versus “Absolute Ownership”: A Comparative Analysis," Perspectives in Law, Business and Innovation, in: Ownership of Trust Property in China, chapter 0, pages 37-75, Springer.
    • Handle: RePEc:spr:perchp:978-981-10-5846-2_3
    DOI: 10.1007/978-981-10-5846-2_3
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