文章比较分析了两国改革开放后的产业结构状况,从立法价值与立法结构方面比较分析了两国外资立法的特点。从鼓励外商投资的措施及税收等方面的特点,比较了两国外资立法具体制度的不同。 The article comparatively analyzes the industrial structure after the reform and opening up in both countries and compares the characteristics of the legislation on foreign investment between the two countries in terms of the value of the legislation and the legislative structure. From the aspects of measures to encourage foreign investment and taxation, the differences between the specific systems of foreign investment legislation of the two countries are compared.