Пенсионный траст как форма трансграничного накопления и движения капитала в английском праве
Present article is dedicated to the consideration of peculiarities of pension trust as a form of cross-border accumulation and movement of capital within the lifetime and causa mortis in English law. According to the doctrine the pension trust has much in common with family trust in its origin, but due to particular characteristics of labour relations and influence of social security law this legal concept evolved into direction of administrative and prudential regulation incorporating some special features unusual for tradtional trust. In present article the author analyses cross-border functioning of the pension trust, which makes it possible to acquire wealth by means of recurrent contributions for senior citizenship and to the benefit of surviving relatives and future generations. The foreign element gives the pension trust some unique competitive advantages and makes the natural person who chose this financial product more flexible in selection of domicile and carreer. The author pays special attention to the pan-european regulation of international pension schemes, implementation of EC directives, interconnection and interaction between the current legal order in the EC and English concept of pension trust.