Plural Legal System under a Unitary State: Jurisdictional Conflicts in Cross-Border Commercial Disputes in the Greater Bay Area and Lessons from the EU Experience

For historical reasons, significant differences exist between the legal systems of Guangdong, Hong Kong, and Macau. This article examines how these jurisdictional conflicts can lead to parallel litigation and forum shopping, wasting judicial resources. Drawing on a comparative analysis with the EU Brussels Treaty, the study proposes a model framework for resolving cross-border commercial disputes in the Greater Bay Area. The article employs doctrinal and comparative legal methodologies to provide practical recommendations for harmonizing regional legal practices without compromising the “One Country, Two Systems” framework.