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反致概念起源于19世纪末一个涉外亲属法中的继承案件。从其发端到现在,已经历一百多年的历程,随着时代发展,反致制度在世界各国国际私法体系中的地位也发生着巨大的变化。在涉外亲属法特别是民事身份领域,反致制度一直发挥着重要的作用。2011年在我国最新施行的《涉外民事关系法律适用法》中对反致制度的取舍显得格外慎重。
Anti-concept originated in the inheritance of a foreign relative law in the late 19th century. From its origins to the present, it has gone through more than 100 years of history. With the development of the times, the status of Anti-DPRK system in the system of private international law in various countries in the world has undergone tremendous changes. In the field of foreign relatives, especially in the area of civil status, the Anti-Settlement System has always played an important role. In 2011, the newly adopted Law on the Application of Law in Civil Relations Concerning Foreign Affairs appeared to be particularly cautious in the choice of anti-dictatorial system.