The Comparison Research Of Officials Property Declaration System In Hong Kong, Macao, Taiwan, Mainland China

As the "sunshine law", the officer property declaration system of the effect of the prevention and punishment of corruption, has been proved in many countries and regions of the world.Hong Kong, Macao and Taiwan regions of the system has been implemented for a long period of time, released from the transparency international corruption perceptions index data as you can see, the three areas of property declaration system has achieved good results. In mainland China since the 1980 s to establish the system of suggestion, after 20 years of development, the system of the pilot areas team is growing, but the mainland has yet to establish a national public servant property declaration system. Hong Kong, Macao, Taiwan and the mainland people who share the same culture. Mainland to truly establish a public servant property declaration system, can be closely interlinked and communication as the link of culture, draw on the experience of beneficial results of Hong Kong, Macao and Taiwan. In view of the political and legal system of the mainland, Hong Kong and Taiwan has a lot of differences, analysis of the four officials property declaration, compare the differences and advantages and disadvantages of system development, is the political cultural exchange and inheriting the perfect samples.Pilot in mainland China in 2009 to carry out the public officials property declaration system, after more than ten years of development, it has obtained some experience, but the effect is not very ideal. How to overcome the weakness of pilot areas of the system and the defect, how to effectively exert the effect of the system to become what scholars constantly think and explore problems. The author based on the analysis on the advantages and disadvantages of Hong Kong, Macao and Taiwan this system, trying to find the suitable property declaration system in mainland China. From Hong Kong, Macao and Taiwan property declaration system of the specific laws and regulations, comparing to four areas the same and different aspects, focusing on the analysis of Hong Kong, Macao and Taiwan the system advantages, mainland pilot of this system is mainly points out its insufficiency, tries to draw lessons from Hong Kong, Macao and Taiwan to improve and advantages of the local service for the mainland to establish the real system.In general to the comparative study of different parts of the same systems including the historical development of the system that is roughly development path.The dispute focus on content comparison, system comparison and system implementation effect and the cause of the compare these four aspects. Writing this article is based on the four basic aspects to Hong Kong, Macao and Taiwan regions and the mainland four comparative study of the system. Mainly in the following several problems:one is the development path, the author thinks that Hong Kong is the government-led public opinion property declaration system development path, the government of the Macao region are the dominant development path. The development path of Taiwan is public opinion and the interests of the parties the development path of combining the system.On the mainland the party and the development path of pilot. Two is the comparison of the system of content, in this paper, the author from the declaration of the main body, declare way and the scope, filing acceptance and declaration and examination way, declare public form accountability and supervision mechanism five aspects to compare. Through the comparison, points out that on both sides of the four officials property declaration on the advantages and disadvantages of these five aspects. For the mainland area tend to main shortcomings pointed out. The comparison is reporting system for dispute focal point. Mainly according to the declaration, lead to declare the subject scope, application scope, the public’s right to know and official definition of privacy, gray income and processing, the transparency of the authority, the public censors and the focal point of the effectiveness of the supervision and accountability, etc, for the perfection of the mainland property declaration system and bring forward comments and Suggestions. Four is the comparison of the system implementation effect and the reasons, on four officials property declaration system implementation effect, to explore the deep reasons behind the implementation effect, mastery of reason, is for the system of Hong Kong, Macao, Taiwan and the deeper analysis, as well as across the country to establish this system in mainland China for reference.