兩岸由於政治環境與歷史發展之因素，對於證券管理法制有別於英美法體 系，又因臺灣證券法制於1953年已初步形成，大陸起步較晚，在兩岸證券爭 議法制仍不完備下，本文就兩岸證券仲裁制度之發展、現行規定及實務案例加 以分析評述，俾供兩岸業界、學界及主管機關就理論與實務了解證券爭議仲裁 制度之缺失，進而早日修法完善制度。

The legal systems governing securities in Taiwan and PRC are quite different from that of common law because of political environment and history development. Taiwan's securities laws were initially enacted in 1953, earlier than the promulgation of the PRC securities laws. As the securities dispute regulations in Taiwan and PRC have not been perfected, this paper analyzes and comments on the development of securities arbitration systems, current regulations, and cases in Taiwan and PRC, so that relevant industries and the competent authority may have a more thorough theoretical and practical understanding to the defects of current securities arbitration systems, and then amend the laws to perfect the systems in the near future.