Trust law in China is rather different from that in common-law
jurisdictions. A trust is not a turnkey product and is definitely
not an off-the-shelf structure, and that is not an easy concept to
understand, especially for Chinese clients who are used to
civil-law concepts and reticent to cede control over their assets
entirely.
Designing a trust structure for Chinese clients requires more
than just technical trust knowledge. Practitioners need to
understand Chinese traditions and culture, explain the meaning of a
common-law trust, and share experiences from other cases where
trusts created decades ago have operated successfully. This article
offers some instructional examples and tips for dealing with
Chinese clients.
