right of setoff 抵销权制度
There are also introduction about banker's right of setoff in common law and civil law, which are used to improve that in China.
我国通说认为，银行扣款还贷是根据《合同法》的规定行使抵销权，包括法定抵销权和约定抵销权。
The right of setoff in law of bankruptcy is based on the seto ff of obligation in civil law, thereby it has some characteristics of that in ci vil law.
破产法上的抵销权源于民法中债的抵销权，故具有民法抵销权的一些特征。
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