أحكام محاسبة الأولياء و الأوصياء في القانونين العراقي و المصري : دراسة مقارنة

الملخص EN

This research deals with the provisions of holding the guardians and trustees to account in Iraqi and Egyptian laws.

Its purpose is to clarify the similarities and differences between the laws of both countries with respect to the subject of the study, in order to take advantage of the strengths points of each law.

To achieve this, the researcher used the inductive analytical, comparative and critical method.

The study concluded with results of; the similarity between the two laws on certain issues, such as not including the fund that devolves to the minor by donation for the accounting provisions if the donor stipulated that, and the differences in other matters.

On the issues of disagreement, the scale of preponderance was in favor of Iraqi law on some issues, such as establishing a special official office to take care of minors' financial affairs and hold the guardians and trustees to account who are negligent.

On other issues, the scale of preponderance was in favor of Egyptian law, such as non-obligating the minor's father to submit the annual and final account about the minor's funds.

Thus, the Iraqi legislature can take benefit from the Egyptian legislator, and vice versa.