当前,我国中小股东权益受到不法侵害的问题屡屡见诸报端,引起国家领导和政府部门的高度重视。笔者希冀通过对两大法系中小股东权保护研究,能对我国的中小股东权保护有所贡献,从而完善我国公司法中对中小股东权益保护的法律制度。一、英美法系对中小股东权的保护措施 (一)强制解散公司这是英美法系解决股东之间争议的传统 At present, the problems that the rights and interests of small and medium-sized shareholders of China are unlawfully infringed often appear in newspapers and give rise to great attention from the state leaders and government departments. The author hopes that by studying the protection of minority shareholders ’rights in the two legal systems, it can contribute to the protection of minority shareholders’ rights in our country, so as to perfect the legal system of protecting the rights and interests of minority shareholders in our company law. First, the Anglo-American legal system for small and medium shareholders’ rights protection measures (A) mandatory dissolution of the company This is the Anglo-American legal system to resolve the dispute between the traditional