beneficiaries would usually have the right to do. Unincorporated Associations A major use of trusts is to allow for the existence of unincorporated associations. These often are associations or groups of people that come together for a particular (usually non-commercial purpose). Common examples might be local social and sports clubs, some gentlemen's clubs, and some professional associations. The main way that English law supports the existence of these is by understanding them as a form of trust. The association has no legal personality (ie the capacity to enter into legal relations in their own name). This contrasts with the approach taken in many civil law jurisdictions, like Spain or France, where civil or social associations are often accorded legal personhood. Thus, in England, the officers of an association (eg. its Chairman, Secretary and Treasurer) will be recognised as trustees and will hold the assets of the association on trust for the members of the association with the constitution of the association forming the basis of the rules governing the trust. South Africa In many ways trusts in South Africa operate similarly to other common law countries, although the law of South Africa is actually a hybrid of the British common law system and Roman-Dutch law. In South Africa, in addition to the traditional living trusts and will trusts there is a "bewind trust" (inherited from the Roman-Dutch bewind administered by a bewindhebber) in which the beneficiaries own the trust assets while the trustee administers the trust, although this is regarded by modern Dutch law as not actually a trust. Bewind trusts are created as trading vehicles providing trustees with limited liability and certain tax advantages. In South Africa, minor children cannot inherit assets and in the absence of a trust and assets held in a state institution, the Guardian's Fund, and released to the children in adulthood. Therefore, testamentary (will) trusts often leave assets in a trust for the benefit of these minor children. There are two types of living trusts in South Africa, namely vested trusts and discretionary trusts. In vested trusts, the benefits of the beneficiaries are set out in the trust deed, whereas in discretionary trusts the trustees have full discretion at all times as to how much and when each beneficiary is to benefit. Asset protection Until recently, there were tax advantages to living trusts in South Africa, although most of these advantages have been removed.