外国竞争法体系的考察及其启示

Foreign Competition Law System Inspection and Its Enlightenment

通过对主要市场经济国家的竞争法体系的阐述,并将其与中国竞争法体系作一比较。美国竞争法律体系以竞争法基本法律为框架,以判例为补充,具有开放性的特点。德国以严密的成文法为特征的竞争法体系,日本的理性的对竞争法体系的分类立法为特色。这都对中国竞争法体系的完善和发展有很重要的借鉴意义。

The paper elaborated on the competition system of main market economy country, and compared it to the Chinese competition law system. The American competition legal takes the competing basic law as a framework, takes the legal precedent as the supplement, and takes the opening as character. Germany takes the strict written law as the characteristic competition law system, Japan rational to the competition law system, takes classified legislation as character. This all has the very important model significance to the consummation and the development of competition law system in China.