香港与内地证券市场的准入制度的比较分析研究

A Comparative Analysis of Access System between Hong Kong and Mainland Stock Markets

香港作为亚太金融中心,其证券市场从十九世纪六十年代股票的自由交易时期开始经过一百五十多年的发展,现在在全球金融体系中占有举足轻重的地位。随着港股通的发展,内地和香港证券市场的融合、互补和共进的效应越来越明显。研究本文目的在于如何借鉴香港证券市场的模式、经验和优势来发展内地的证券市场,而从香港与内地证券市场的准入制度的比较和分析来探讨以上问题是十分重要的。本文正是对香港与内地证券市场准入进行了研究,并侧重于证券机构和上市公司对香港和内地的差异进行比较分析。

Hong Kong, as the financial center of the Asia-Pacific region, has been playing an important role in the global financial system since its stock market began to develop over the past 150 years since the free trading period of the stock market in the 1860s. With the development of Hong Kong stock exchanges, the Mainland and Hong Kong stock market integration and complementarity effect is more and more obvious. The purpose of this paper is to learn from the model, experience and advantages of the Hong Kong stock market to develop the securities market in the Mainland. It is very important to discuss the above problems from the comparison and analysis of the access system between the Hong Kong and Mainland stock markets. This paper studies the securities market access in Hong Kong and the Mainland, and focuses on the comparative analysis of the differences between Hong Kong and the Mainland by securities institutions and listed companies.