Legislative Model Of Chinese And Foreign Audit Oversight System Is A Comparative Study

Audit Supervision, that the State Council establishes an auditing body to supervise through auditing the revenue and expenditure of all departments under the State Council and of the local governments at different levels , and those of the state Financial and Monetary organizations and of enterprises and undertakings. It is the infallible fruitage of the democratic and constitutionalism and it is consequent outstretching of the democratic and constitutional in the auditing field . Also it has multiple values and plays an important role in the deepening the reforms , the regulating of market economy ,anti-corruption and the building of clean government.The Audit Independence ,that under the direction of the Premier of the State Council ,the auditing body independentently exercises its power to supervise through auditing in accordance with the law ,subject to no interference by any other administrative organ or any public organization or individual .It is the lifeline of the audit supervision .The consensus was concluded in so many countries and got emphasized in The Lima Declaration of Guidelines on Auditing Precepts.To help the independence of the Audit Supervision ,when the governments in the world deal with "the Triangular Relations" among the Parliament ..government and the auditing body in order to design a good auditing model ,they adopt various auditing patterns generally including "the Legitimate pattern", "the Juridical pattern" and "the Independent pattern".The article derives from the comparison on the various auditing patterns ,hoping to give some suggestions to our Audit Supervision System in theory and practice .The Legitimate Pattern is the among choice in democratic constitution countries and also it provides an applicable solutions in our current auditing reform.The article consists of introduction and 3 main parts as the following (approximately 35,000 words).Part Ⅰ : The author explains the concept of "the patterns of the Audit supervision systems".Part Ⅱ :The author makes an comparison on the pattern of the Audit supervision systems in the world .Part Ⅲ:The author analyzes the drawbacks in our national current auditing mechanism and the possible policy alternative.