Comparative Study of Special Economic Zones: National Legal Systems and International Perspective

經濟特區比較研究 - 從國家法制和國際視角

Student thesis: Doctoral Thesis

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  • Anton TUGUSHEV

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Awarding Institution
Award date12 Aug 2021


In this dissertation, the author studies the concept of special economic zone (SEZ) as a legal phenomenon within the “law and development” theory. Special economic zones (SEZs) are perceived both as a special legal regime and as a method of social-economic development of remote, underdeveloped territories. This study aims to enrich and develop theoretical discussion on SEZs, but also seeks to compose practical recommendations by looking into implementation practices of these zones around the world.

The theoretical component of this dissertation is represented by endeavours to compare different interpretations of the SEZ concept and compose a universal definition of “special economic zone”. This is accompanied by setting up the essential characteristics of an SEZ and describing a “4-Special” Test for distinguishing SEZ from other legal concepts. As a part of the theoretical analysis, different types of SEZs are studied and new classifications of zones are introduced by the author. Additionally, this research comprehensively looks into the legal nature of SEZs and explains what sources, methods and principles are invoked in legal regulation of business and other activities in SEZs.

The practical component of this dissertation is represented by comparative analysis of experiences and laws in different countries to identify regularities, differences and similarities in SEZ implementation. By using research methods such as historical analysis, case study, normative comparison and interview of practitioners and experts, the author strives to examine the convergence tendency of SEZ regimes around the world and predict trends in their future development. The main research question, which refers to discovering the most efficient SEZ model, is tackled by identifying factors affecting SEZ performance and composing a set of 20 recommendations for the establishment of SEZs in future. This dissertation also concludes that SEZs should be established in accordance with the model encompassing principles of sustainability and regulatory efficiency. These principles are an essential part of the “Conceptual Framework of Special Economic Zone” which has been developed by the author in this dissertation.