In certain civil law jurisdictions (e.g.,

France France, officially the French Republic, is a country located primarily in Western Europe. Overseas France, Its overseas regions and territories include French Guiana in South America, Saint Pierre and Miquelon in the Atlantic Ocean#North Atlan ...

Quebec Quebec is Canada's List of Canadian provinces and territories by area, largest province by area. Located in Central Canada, the province shares borders with the provinces of Ontario to the west, Newfoundland and Labrador to the northeast, ...

Mexico Mexico, officially the United Mexican States, is a country in North America. It is the northernmost country in Latin America, and borders the United States to the north, and Guatemala and Belize to the southeast; while having maritime boundar ...

, etc.), the patrimoine d'affectation is

property Property is a system of rights that gives people legal control of valuable things, and also refers to the valuable things themselves. Depending on the nature of the property, an owner of property may have the right to consume, alter, share, re ...

, assets, or a legal estate that can be divided for a fiduciary purpose, as being distinct from a person's general assets. It is similar in some respects to the way under

common law Common law (also known as judicial precedent, judge-made law, or case law) is the body of law primarily developed through judicial decisions rather than statutes. Although common law may incorporate certain statutes, it is largely based on prece ...

property is held, managed, or invested in

trust Trust often refers to: * Trust (social science), confidence in or dependence on a person or quality It may also refer to: Business and law * Trust (law), a legal relationship in which one person holds property for another's benefit * Trust (bu ...

by a trustee for the benefit of third parties (beneficiaries). The affected property remains outside the grantor's assets; therefore, even if the grantor goes bankrupt, becomes insolvent, or incurs liabilities, the property remains untouchable and may continue to benefit the intended beneficiaries. Originally proposed as a way of explaining the common law trust, the concept was first put forward by the French jurist Pierre LepaullePierre Lepaulle, ''Traité théorique et pratique des trusts en interne, en droit fiscale international'' (Paris: Rousseau et Cie, 1932). who based it on the German .

References

Civil law (legal system) {{Law-stub