一国两制是事关祖国统一的基本国策,也是处理包括两岸民商事法律适用问题在内的两岸关系的根本指导思想。本文立足现实,参照国际惯例,探讨在“一国两制”架构下海峡两岸民商事区际私法的框架体系。 The principle of “one country, two systems” is the basic national policy concerning the reunification of the motherland. It is also the fundamental guiding principle for handling cross-Strait relations including the issue of the application of the law on civil and commercial affairs across the Taiwan Strait. Based on the reality and referring to international practice, this article explores the framework of the private law of civil and commercial areas across the Taiwan Strait under the framework of “one country, two systems ”.