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中国(包括台湾地区)、日本都属大陆法系,两国的法律体系及制度存在很大程度类似,行政法体例上亦然,但种种原因使得彼此间又有较大差异。就行政强制制度而言,在行政强制执行方面,执行内容和方式两个标准下两国执行主体存在较大差异;从行政强制措施方面,两国差异较小,均以行政机关为主要强制主体。
China (including Taiwan) and Japan are both civil law jurisdictions. The legal systems and systems in the two countries exist to a very large extent similar to those in administrative law, but there are quite a few differences between them because of various reasons. For the administrative compulsory system, there are big differences in executive enforcement between the two countries in terms of administrative enforcement and the content and mode of enforcement. From the point of view of administrative coercive measures, the differences between the two countries are relatively small, with the executive authorities as the main coercive body .