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美国与欧盟分别拥有世界上最发达的竞争法。在经济全球化背景下,欧美竞争法在具体适用中产生了激烈冲突。通用/霍尼韦尔等系列并购案暴露了现有国际竞争合作及监管机制的严重不足。因此,建立并完善双边竞争合作机制,进而将竞争问题纳入世贸组织框架将是协调各国竞争立法的一个发展趋势。
The United States and the European Union each have the most advanced competition law in the world. Under the background of economic globalization, the competition law of Europe and the United States has had fierce conflicts in its concrete application. A series of mergers and acquisitions, such as General Motors and Honeywell, revealed a serious shortage of existing international competition cooperation and regulatory mechanisms. Therefore, setting up and perfecting bilateral cooperation mechanism of competition and then bringing the competition issue into the WTO framework will be a development trend of coordinating the competition legislation of all countries.