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香港、澳门回归后,中国在事实上已成为“一国两制三法系四法域”的复合法域国家。中国的区际民商事法律冲突是在特定的历史条件下形成的一种客观现象,在实际案件处理过程中,香港与内地并没有真正做到协商一致,反而在许多具体环节上存在着严重的冲突情况,此问题应得到中央及最高司法机关的高度重视,尽快完善有关立法,避免因法律不完备而给人民法院审理涉港案件带来不必要的负担和难题,给两地人民的经济交往造成不便,损害内地与香港经贸关系的健康发展。
After the reunification of Hong Kong and Macao, China has, in fact, become a compound law country of “one country, two systems and three laws and four jurisdictions.” China’s interregional civil and commercial law conflicts are an objective phenomenon formed under certain historical conditions. Hong Kong and the Mainland did not really achieve consensus during the actual handling of cases. On the contrary, there were serious Conflict situation, this issue deserves the great attention of the Central Government and the highest judicial organs, improve the relevant legislation as soon as possible, and avoid unnecessary burdens and problems that the people’s court will bring to the people’s courts when handling cases involving Hong Kong as a result of incomplete laws, and give economic cooperation to people in both places Cause inconvenience and jeopardize the healthy development of economic and trade relations between the Mainland and Hong Kong.