ABSTRACT
Trusts are very significant in international commercial activity and they are wonderful in tax-avoidance structures. One of the principal interactions between commercial law and equity has been a desire on the part of commercial lawyers to keep equity out of commercial cases. There are two principal themes in international trusts law such as: the Hague Convention on the Recognition of Trusts, and the use of trusts for tax-avoidance purposes in international trusts law practice. There is an important question within a field of law known as 'private international law' as to whether or not a trust created in one jurisdiction under that jurisdiction's system of law would be enforced in another jurisdiction which had no trusts law or which had different trusts law. Private international law is part of English law. The 'governing law' means the system of rules which are used to interpret the trust, the rights of the beneficiaries and the duties of the trustees.
