quality:corruption, linguistic:voice_change
Chinese contract law

There are four distinct systems of contract law presently in force in China, three of which are in force in different regions administered by the People's Republic of China and one of which is in force in the Republic of China. In the People's Republic; Hong Kong is a common law jurisdiction whose contract law is largely identical to the pre-1997 contract law of England and Wales, Macau operates under a distinct framework modelled after Portuguese civil law, and contract law in the Mainland is governed by the 2021 Civil Code of the People's Republic of China. In contrast, contract law in all areas of the Republic of China are governed by the Civil Code of the Republic of China which was originally modelled after the Japanese Six Codes system, itself primarily based on the German pandectist approach to law.