In the article the author investigates the peculiarities of trusts and trust-like constructions in Scotland, the Canadian province of Quebec and the South African Republic. Each of these countries (territories), due to various historical, economic and other reasons, combines the essential features of civil and common law, that’s why they are known in comparative law as mixed jurisdictions. This situation has led them to creation completely unique legal institutions which can achieve the same results as English trust, while taking into account national specificity.