Summarise:

The law relating to the private international aspects of trusts is underdeveloped to say the least and ‘anything like an attempt at systematic exposition would be premature’. All that can be done is to set out some of the principles which ought to be applicable to such
cases. As elsewhere in the law of property, the distinction between movables and immovables dominates the law. Three further aspects should be kept clearly distinct, however.

The law regarding private international aspects of trusts is not well-developed and a systematic exposition is premature. The distinction between movables and immovables is important, but three additional aspects should also be considered separately.