跨国资产证券化是近几年新兴的资本融资方式,有关它的法律适用,学界众说纷纭。本文试图从两种对立的理论观点入手,结合各国实践中存在的问题,得出了“从各国国内法入手,探讨跨国资产证券化的法律适用问题,以减少因法律适用的不确定性而增加的交易成本”的初步结论。 Transnational asset securitization is a new form of capital financing in recent years. There are many opinions about the application of its law. This article attempts to start from two opposite theoretical points of view, combined with the problems existing in the practice of various countries, come to “from the national law of various countries to explore the legal application of cross-border asset securitization in order to reduce the uncertainty of the law and Increased transaction costs ”the initial conclusion.