随着我国社会主义市场经济的不断发展 ,各种资源的配置也进一步市场化 ,有限责任公司股东出资的转让也愈加频繁 ,随之产生的纠纷也很多。从几年来此类案件的数量上可以看出 ,其中一个很重要的原因在于我国《公司法》等相关立法规定不周全、不完善。本文拟在比较一些主要大陆法 With the continuous development of the socialist market economy in our country, the allocation of various resources is further marketized. The transfer of capital contributed by the shareholders of limited liability companies is also becoming more frequent, resulting in many disputes. Judging from the number of such cases in recent years, one of the most important reasons for this is that the relevant legislative provisions such as the Company Law of our country are not comprehensive and imperfect. This article intends to compare some of the major continental law