通说认为,基于遗赠的请求权与各国所采取的遗赠立法模式息息相关。本文认为不同的立法模式对遗赠的概念、功能不尽相同。从基本概念、法律功能等方面进行比较法研究,可以得出遗赠仅具有债权效力。 It is generally believed that the bequest-based claims are closely linked with the bequest legislation adopted by all countries. This paper argues that different legislative models have different concepts and functions to bequests. From the basic concepts, legal functions and other aspects of comparative law, we can conclude that bequests only have the effect of claims.