内地与香港对上市公司收购监管之比较——兼议我国《证券法》的完善

Comparison of Regulation on Takeovers of Public Companies Between Mainland And Hong Kong——Study on the perfection of Security Law of the Mainland

上市公司收购是重大的证券交易活动 ,各国均对其实行一定程度的监管 ,以维护整个证券市场的稳定。香港《守则》规制详尽完整 ,并具很强的可操作性 ,我国《证券法》则粗略得多 。

The takeovers of public companies are important security transaction activities,so different countries all have certain degree regulations on them in order to maintain the stability of the whole security market.The thesis make a comparison of the regulation on takeovers of public companies between the Mainland and Hong Kong from three aspects of disclour of information,mandatory offer takeovers and anti-takeover measures.I hope the thesis can benefit the perfection of Security Law of The Mainland.