Category Of Management: Comparative Legal Analysis According To The Legislation Of The Countries Of Anglo-Saxon And Continental Legal Families

  • A.A. Albu
Keywords: confidential property asset management, manager, trustee, beneficiary.


The article analyzes the category of management, its civil-law forms through the use of legislation of the countries of Anglo-Saxon and continental legal families. The author examines and analyzes the laws of the United Kingdom, the Russian Federation and Ukraine. On the basis of the conducted research, conclusions were made on the improvement of the current legislation of Ukraine.

It is established that the essence of the relationship of trust (trust) under Anglo- American law is that one person - the founder of the trust property who owns the property, transfers his property to another person - the trust owner to manage in the interests of the named person - the beneficiary. The essential condition of trust (trust) is the splitting of ownership, when the ownership of the property belongs to one person (the trust installer), the right to acquire benefits - another (the manager), and the right to receive them - to a third person (the beneficiary).