The Application Issues and Improvement Approaches of Differential Voting Rights System —From the perspective of comparing domestic and foreign practices

With the rapid development of science and technology industry, the traditional principle of "one share, one right" has limitations, and differentiated voting rights have emerged because of its advantages such as meeting the heterogeneous needs of shareholders, resisting hostile takeo-vers and guaranteeing corporate financing. The practice of differentiated voting rights in coun-tries such as the United States, Japan, Singapore and Canada and China is different in terms of regulatory models, information disclosure and sunset clauses. However, the differentiated vot-ing rights system may lead to the increase of agency cost, the lack of supervision mechanism and the intensification of moral hazard in practice. In order to improve the system, the information disclosure mechanism should be improved, the fiduciary duty of controlling shareholders should be strengthened, and a "time-type sunset clause" should be introduced to balance the in-terests of all parties and promote the optimization of China's business environment.