透過對《戶部則例》、《吏部處分則例》與《大清律例》相關條文的細緻 比較，本文將論證以下一項核心命題：明朝與清朝財政制度雖然都屬黃仁宇 分析的「原額主義財政」(Quota System)，但這其實是需再進一步檢證的表 像；明清兩朝財政制度其實存在重要差別：明朝財政「主要以增稅為對策」， 故而「加派」就顯得十分重要；而清朝財政則「主要是以降低財政赤字為對 策」，故而是以解決「民欠」和「虧空」兩項問題為關鍵。簡言之，明朝財 政的基本規範，仍是宋代以來所謂「舊管＋新收－開除＝存庫」的四柱式計 算公式，這個算式僅能顯示實際徵收財貨在政府會計期間之內的出納情形， 並不特別強調「原額」，故而無法稱為「嚴格意義的原額主義」。 本文援用岩見宏對明朝財政所做分析為立論基礎：明朝中期以前，政府財 政主要依據課徵田賦或徭役之際的賦役黃冊或魚鱗圖冊等「底帳」，這些底 帳僅是徵稅時的參考，並不真能實際規範地方財政的運作；但到明代後期， 各地逐漸出現了大量刊行的《賦役全書》，自此之後，所謂的「原額」才能由理論走向實際，產生了「較強固的規範性」。清代繼承了晚明編刊《賦役 全書》的傳統，因而，「嚴格意義的原額主義」也才能由明代後期到清代被 真正地落實。 正因為明代中期以前「原額」沒有《賦役全書》為基礎，故各地「加派」 現象頻繁發生；而為了保障晚明以來編刊《賦役全書》以貫徹「嚴格意義的 原額主義」之基礎，清代財政法規比明代更加重視維護「原額」，如何更有 效地解決「民欠」與「虧空」問題？也便成為清代法律的重要規範目標。本 文詳細比對《戶部則例》、《吏部處分則例》與《大清律例》有關「民欠」 與「虧空」的各種相關條文，以證成清朝財政的運作已與官員考成與勒限追 補做了更緊密結合；正因如此，清朝的「原額主義財政」實際上已更加融入 針對官員而特別製訂的行政處份與法律刑責之中，這也構成其與明朝財政體 制極為不同的特徵。

Both the Ming and Qing fiscal systems belong under the category of the quota system analyzed by Ray Huang. However, there are key differences between the Ming and Qing systems. Ming financial policy focused on increasing revenue, primarily through raising taxes. The Qing mainly sought to reduce deficit; particular importance was placed on solving the problems of minqian (tax arrears) and kuikong (deficits of the treasury). In the Ming, the financial condition was calculated by the formula for the so-called sizhuce (four-column record), which was inherited from the Song dynasty. This formula reads as follows: jiuguan (balance forwarded) + xinshou (new receipt) – kaichu (outlay) = zunku (present balance). This formula only calculated the actual revenue and expenditure for a given fiscal year, but did not touch on the “quota.” Therefore, the fiscal system in the Ming is not a quota system in the strict sense of the word. According to Iwai Hiroshi’s analysis of Ming dynasty financial documents, until the middle of the Ming, fiscal administration depended on the basic registers (such as the Yellow Book and the “Fish Scale Book”), which were used when the government imposed taxes or service levies. During the latter half of the Ming, each province and independent prefecture compiled a “Comprehensive Book of Taxation and Service Levies,” which did not only reflect the actual financialconditions, but also controlled them rigidly. Thereafter, the quota system that had heretofore been a theoretical ideal was put into practice. The Qing dynasty took over the result of this late Ming reform, and it was only then that the quota system was finally established. During the Ming, because tax quotas failed to control taxation effectively, taxes were frequently increased. On the other hand, the Qing strictly maintained tax quotas; therefore, minimizing tax arrears was one of the main policies of the Qing. During the Qing, tax quotas were established as goals that tax collectors were required to attain. However, it was difficult for officials to collect the full amount of taxes. As a result, Qing financial regulations primarily outlined the disciplinary punishments for failure to collect the proscribed amount of taxes as well as listing the procedures for covering treasury deficits. This paper examines the articles concerning minqian (tax arrears) and kuikong (deficits of the treasury) in the Regulations of the Board of Revenue, the Punitive Regulations of the Board of Civil Office, and the Penal Code. Based on this research, it is clear that financial regulations in the Qing dynasty (unlike the Ming) were inseparable from personnel management.