Nekit K. Property trust management agreement: comparative-legal analysis on the basis of the materials of Ukraine, Republic of Moldova and Russian Federation.

Thesis covers complex civil investigation of the property trust management agreement by comparative analysis of the legislation of Ukraine, Republic of Moldova and Russian Federation, as well as determination of the tendencies and means for improvement of legal regulation of the relations arising from the property trust management agreement. Origin of trust structures in the Roman private law and their development in derivative European systems of civil law are analyzed. Based on the results of the analysis of doctrinal regulations and legislation of Ukraine, Republic of Moldova and Russian Federation the peculiarities of becoming of this institute in the civil law of stated countries, common and differential characteristics of the legislative recognition of property trust management agreement, as well as its features and specificity are determined. Peculiarities of the legal status of property trust management subjects, the object, subject and procedure for conclusion and termination of the property trust management agreement, as well as parties’ responsibility under the legislation of the analyzed countries are discussed. The recommendations for improvement and application practice of the legislation were formulated on the basis of the analysis of scientific literature, normative-legal acts and judicial practice.