| The thesis is mainly analyzed and generalized by the comparative study with discussions. It aims to explicate and analyze the dissertations, periodicals and study reports concerning the stock exchange systems in Taiwan, Mainland China and Hong Kong. Through evaluating the predominance in these places, we expect to build up a more solid stock market by improving our own defects and weakness. The thesis is composed of 5 chapters. The first chapter probes into the current security law in Mainland China from which we can realize the interpretation and analysis of the related policies of China stock market.The second chapter talks about the security law in Taiwan from the definition of the stock, supervision organization, the exchange system, management of the dealers, security exchange center, to the information disclosure and market operation so as to understand the regulations carrying out in the stock market of Taiwan.The third chapter will compare and contrast the stock exchange system both in Taiwan and Mainland China. This part will illustrate the discrepancies in the definition of the stock, the issue system, the management of the dealers, the exchange system, disclosure of information, forbidden behaviors, the return of internal illegal interests, acquisition, the stock exchange corporation, arbitration, and so forth.The fourth chapter lays stress on the management of the stock exchange in Hong Kong. The effective method which the Hong-Kong authority concerned adopts is the strict and rigorous supervision complying with the security law. The financial supervision of the government and the stock exchange corporation unify together into an integrated system. The Unified Exchange which manages by itself is a fairly important component of the Hong-Kong stock supervision system and turns out to be the international financial center after revising the regulations several times. The fifth chapter focuses on the comparison of the stock exchange system between Hong Kong and both sides. According to the previous introduction of the security law in each place, this chapter here will present the content by charts so that the main points on several comparisons can be easily picked up.The sixth chapter which is also the conclusion of the thesis mainly expounds that the evolutionary process of the stock market between both sides are so different that the scheme of the market mechanism will be divergent. Therefore, this thesis primarily probes thoroughly into the discrepancy in the security law between both sides. Nowadays the government in Mainland China intends to reform the flaws in the stock market so as to assure full disclosure and open information regarding the regulations, and stock exchange system. Moreover, the Stock Exchange of Hong Kong Limited (SEHK) loosens the restrictions of entering the market and start business at the first time for Hong Kong expects to solidify its financial status. If the stock market of Taiwan still can't highlight its predominance, the development of the stock market in Mainland China and Hong Kong will lead the way.By research into overseas legislations concerning takeover and takeover defense, and based on our country's present situation, the dissertation makes a relatively objective evaluation of takeover defense and puts forward some suggestions on how to perfect the policy-making right in takeover defense and management level's duty system of our country's objective company.The dissertation consists of three parts——the preface, the text and the ending. The text covers four chapters:The first chapter is the discrimination of concepts in takeover defense of company. It comprises of three parts: the first part expounds mainly some basic concepts in takeover defense of company, and introduces slightly main content involved in takeover defense in order to complete it. The second part is arguments of value over takeover and takeover defense. The third part involves evaluation of takeover defense and by analyzing two mainstream viewpo...
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