The Development of “Trust‐like” Mechanisms in Today’s Bulgaria, the Czech Republic and Romania

Irina Gvelesiani

The concept of “trust” originated in English Common law during the Middle Ages. It derived from a system employed in that era known as “use of land” or “uses”. “Trust” considered the transference of the “trustor’s” property to the “trustee” who managed it for the benefit of the so‐called “beneficiaries”. At the beginning of the 19th century, “trust” emerged in the business sphere of the USA, whilst at the end of the 20th century the growing world‐wide importance of American capital markets stipulated the appearance of “trust‐like” devices throughout Europe. Despite some contradictions, different modifications of “trust” have entered into Bulgarian, Czech and Romanian law. This chapter will study the evolution of these newly established institutions, and attempt to predict their influence on juridical processes and determine their role in the integration of the 21st century European juridical system. This research is based on theoretical data. Its outcomes will be useful for lawyers of different countries of the world.