股东因向公司出资而享有股权,由于公司具有社团性,特别是有限责任公司以股东间的信任关系作为成立基础,而某一股东的股权转让行为必然或多或少的影响这一信任基础,所以各国公司法对有限责任公司股权转让行为均设有不同程度的限制。我国《公司法》对股权转让设置了较为系统的规定,但仍有一些不足和有待完善之处,通过对各国公司法的研究,笔者将提出建设性的建议。 Shareholders share equity due to the company’s contribution. Due to the corporate nature of the company, especially the limited liability company based on the trust relationship between shareholders as the founding foundation, and the equity transfer behavior of a certain shareholder is bound to be more or less affected, Therefore, the corporate law of each country has limited restrictions on the equity transfer of limited liability companies. China’s “Company Law” has set more systematic rules on the transfer of equity. However, there are still some shortcomings and areas for improvement. Through the study of company law in different countries, the author will make constructive suggestions.