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在大陆法系的法典体系中,物权法是其中很重要的环节。物权法涉及到所有主体权利指向的客体种类、权利范围、变动方式等多种内容,本文集中讨论几国物权变动的方式和相应的物权行为理论。在社会经济发展到一定阶段,各种物品的权属有较为明确的规定能够减少纠纷,我国作为一个继受西方法律又急需调整物品权利归属的国家,对于大陆法系国家的物权变动方式和物权行为理论有所了解是十分必要的。
In the legal system of the civil law system, the law of property is one of the most important links. The Property Law involves many kinds of objects, such as the types of objects, the scope of rights and the ways of change of the rights of all the subjects. This article focuses on the ways of the changes of the real rights in several countries and the corresponding theory of the real rights and interests. In a certain stage of socio-economic development, the ownership of various items has more specific provisions to reduce disputes. As a country which is in urgent need of adjusting the ownership of articles in Western law, Some understanding of real rights and behavior theory is very necessary.