The subject of this article is the experience of countries that belong to the Roman-German legal family and have borrowed a trust, an alien institution for their legal system. The author focuses on the fact that the trust has been repeatedly rejected on the continent on the grounds that the dichotomous title is fundamentally incompatible with the unitary model of ownership within the continent and the restrictions that the law imposes on possible legal titles to property. However, some continental countries have realized that it is difficult to satisfy the interests of society by remaining within the same model of property rights, so the assumption of splitting property rights in certain legal relations is necessary today.