A Comparative Study of the Principles, Structure and Function of Endowment in Iran Law and Trust in English Law

The Endowment is one of the methods of transferring property that is used for benevolent and charities purposes in Iranian law, and Trust is one of the methods of transferring property in British law, which is both for transferring ownership and transferring benefits to certain persons and also for charitable purposes Or used for other purposes. Both of them have similarities and differences in terms of owner purpose, structure and function. Their similarity is that the property ownership is taken away from the original owner, and the original owner will have no ownership rights of the property and interests, and another similarity is that a trustee is elected to manage the property, and another similarity is that If the original owner's orders can be carried out, they will be acted upon, and if the orders cannot be carried out or he/she has not given any orders at all, Trustee will act according by law. And their difference is in the status of the transfer of ownership. In this article, we intend to compare these two legal entities in terms of principles and foundations of its formation, structure and function.

Keywords:

Endowment in Iran Law , Trust in English Law , Comparative Law , Beneficiary , Trustee