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日本、德国、美国的受益者负担金制度有较长历史和正统法源。日德中央立法与地方立法相辅相成,美国则无联邦立法,相关法制和纠纷多停留于州法和州法院。关于负担金标准,美国采用单一思路,日德则视情况区别对待。受益者负担金制度应用在日美历史上出现过起伏,而在德国运行较为平稳。日德美受益者负担金制度的立法与实施经验可为我国借鉴,可以理性地、渐进地导入该制度。
Japan, Germany, the United States beneficiary burden system has a long history and orthodox sources. Central and Japanese legislation is complementary to local legislation, and the United States has no federal legislation. The relevant legal systems and disputes remain in the state and state courts. Regarding the standard of contribution, the United States adopted a single line of thinking while Japan and Germany treated each differently. The application of the beneficiary contribution system has experienced ups and downs in the history of Japan and the United States, while the operation in Germany is relatively stable. The experience of the Japan-Germany-United States Beneficiary Payment System’s legislation and implementation can be borrowed by our country and can be rationally and gradually introduced into the system.