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This thesis has been written to fill a gap in the field of investment law as no comparison existed in connection with Hungarian and Chinese investment regulations since the last andonly work of a Chinese author done in 1995. This work is becoming more and more actual and timely because there are vivid and developing economical and trade relationships between China and the European Union. Hungary also has increasing interest in mutual investments with China but there is little information available from the legal approach for businessmen of both countries. Among these the system of allowances have major importance for those wanting to invest either in China or in Hungary. Besides putting light on the historical background, this work focuses on the practical issues through the similarities and differences of the two incentive systems and helps potential investors to appear on the Hungarian or the Chinese market.