从欧盟《结算终局性指令》到美国《统一商法典》,再到海牙国际私法会议制定的《关于中间人持有证券特定权利的法律适用公约》,跨境证券交易的法律适用的PRIMA原则,其形成和发展经历了一个较长的立法与实践过程,有必要厘清其内涵和外延。经过实践检验,PRIMA原则展现出了其相比传统法律适用原则的优势,也暴露出其不足之处,对其进行一个客观的分析评价具有重要意义。 From the EU “final settlement directive” to the United States “Uniform Commercial Code” to the Hague Conference on Private International Law "on the holders of specific rights of securities holders of the Convention on the Law Applicable to PRIMA principle of cross-border securities transactions applicable law, its Formation and development have undergone a long process of legislation and practice, so it is necessary to clarify its connotation and denotation. After practice test, the principle of PRIMA shows its advantages over traditional principles of law application, and also reveals its shortcomings. It is of great significance to carry out an objective analysis and evaluation.