论中国大陆与港澳台地区遗嘱继承的法律冲突及解决-法学；国际法学专业论文.docxVIP

IV IV discrimination between the international conflicts and the interregional conflicts. But so far there is no special law on interregional conflicts on the testamentary succession. The international rules of conflicts in “Macau Civil Code” should be applied by analogy to resolve interregional conflicts. Taiwan is the most abundant area of the adjustment legislation on the interregional conflicts. On July 31, 1992 Taiwan authorities announced the “Taiwan Area and Mainland Area Relations Ordinance ” ， and amended several times. The current is the “regulations” promulgated on July 1, 2009. By comparing the conflict rules on testamentary succession of various regions, we could find the common ground and provide reference for the unity of the conflict rules of testamentary succession. Interregional testamentary succession conflicts belong to interregional civil conflicts, solved by conflict laws or by unity substantive laws. The unity substantive laws method seems to still only be viewed as an ideal. It is impossible. In the conflict laws approach, we could continue to employ their existing settlement means, or to reach regional arrangements, or to develop a unified law of the interregional conflict of laws. From a practical point of view, whether continuing to employ their existing settlement or developing a unified law, reference to the Hague International Convention (mainly referring to the “Convention of 5 October 1961 on the Conflicts of Laws Relating to the Form of Testamentary Dispositions” and the “Convention of 1 August 1989 on the Law Applicable to Succession to the Estates of Deceased Persons”) is the most feasible method. In terms of regional arrangements, the purpose should be the actual enforceability of the arrangement, and the full protection of the individual regions and citizens interests. Keywords: testamentary succession; interregional conflicts of laws; Hague Conference Convention 她创性声明 本 人 声哨，1忏穿 史 的学垃论吏是本 人在导 师指导 F 进厅 的明克j_作J