Although the trust is one of the most important institutions of Anglo-American law and holds significant importance in international transactions, its legal structure often remains unclear. This is particularly difficult to understand for the Roman-German legal sphere. This work examines the legal structure of the English trust and compares it with the Roman fiducia, the fiduciary trust, the fideicommissum, and the trust under Scottish law. The studies for this work were largely conducted at the universities of Oxford and Edinburgh. This allowed for a fundamental investigation of the trust, including its historical development, making its legal structure more explicable and understandable.