India-the ancient civilized nation of BRICs is rising gradually with its unlimited amazing potential and explosive force. According to the GDP computation from the World Bank 2005 report, Indian¡¦s economical scale amounts to 692 billion US dollars. This has ranked India the 10th biggest economy in the world. Toward the international enterprises, India is filled with the infinite business opportunities and has already become the spotlight in the global economy. In the past, Taiwan enterprises often put their focus on mainland China, and directly neglected this emerging market, India. On the contrary, the enterprises from Europe, America, Japan, Korea, and even China have entered India and also planned their layout positively one after another. However, Taiwan enterprise¡¦s footsteps are relatively slower. Although the economic interaction between Taiwan and India is not as much as other countries, India government has recognized that Taiwanese enterprises had played a great catalytic and accelerated role in the economic development process of mainland China. Moreover, the technical advantages and the market experiences from Taiwanese economy development are corresponding to the necessity of the economic development of India nowadays. Therefore, the cooperation between Taiwanese enterprises and India could achieve the complementary effect and the mutual benefit in India economy development. Also, Taiwan government has already established a Taiwan-India Cooperation Council in 2006.This platform would be an integrator for the bilateral interactions between India and Taiwan. Right now, under Taiwan government and NGO assistances, Taiwanese enterprises could fully elaborate the core competitions, the technical advantage and market experiences, and contend for the international stage. This research is based on exploring the study of international trade theories, international investment theories and international market entry strategies, then matching with the observation and the business visit of current India market. The following points of view are the conclusion from this research: 1. Further understanding of the economic development of India market. 2. Further understanding of the development of India states and industries. 3. Finding out the business opportunities for Taiwanese enterprises during India¡¦s economy development. 4. Finding out the available entry strategies for Taiwanese enterprises in India markets. Key words: Taiwanese enterprises, India market, entry strategies.

This study investigates how the subsidiaries of multinational enterprises (MNEs) reconfigure their resource bases to respond to an altered strategic positioning. In particular, the focus is on the subsidiaries of multinational enterprises from emerging economies (EMNEs), which undertake transformation from export-orientation to host market-orientation in an emerging economy being host country. Two Taiwanese MNEs with subsidiaries in China extensively operated the host market are selected as case studies. This research is grounded in a preliminary conceptualisation covering three main areas: subsidiary organisations, external actors in the host country and headquarters’ functions. It provides insights into (1) how the subsidiaries align their historical resources with newly-developed capabilities; (2) how the subsidiaries govern inter-firm relations with external actors in the host environment; and (3) whether and how complementary resources are to a limited extent transferred from headquarters to subsidiaries so as to support the operations in the host market. With regards to the organisational initiatives undertaken by the case subsidiaries, it is found that the historical resources are leveraged to support the host market business, whilst at the same time developing required marketing capabilities. In addition, the concept of organisational ambidexterity is adopted to refer to way in which existing (export-oriented) and new (host market-oriented) businesses that are operating simultaneously. As to the inter-firm relations, the case subsidiaries have been mainly governing their relations with distributors by performance-based mechanisms aiming to secure stable profits. By contrast, the relation-based trust was not commonly observed among the cooperation ties. With growing brand strengths and increased direct contact with consumers, they held higher authority over the interfirm relations with distributors than during the initial stages of operating in the Chinese market. In addition, with regards to the cross-border resource transfers, two distinct modes of headquarters-subsidiary relationships emerged: a traditional one, in which headquarters allocate resources within MNEs and a novel one in which headquarters’ functions were gradually replaced by the powerful subsidiary, termed in this thesis as “migrating headquarters”. On the basis of these findings, we put forward a set of propositions that present the interrelations between the resource circumstances of case subsidiaries, the institutional environments and the organisational initiatives undertaken by the case subsidiaries. Theoretically, the contributions of this study are threefold. Firstly, it advances the research on subsidiary development by holistically exploring the: resource reconfiguration of subsidiaries, inter-firm relations with external actors and headquarters-subsidiary relationships. In particular, the resource deficiency which the EMNEs’ subsidiaries encountered and the characteristics of the required capabilities for the host market-oriented transformation, i.e. local marketing competences, were investigated. Secondly, through probing the governance mechanisms adopted regarding interfirm relations between the case subsidiaries and local distributors, this study not only addresses the question of how MNEs acquire this location-bound resource, but also advances the extant research by the aspect of network positions. That is, this study indicates that the first-tier distributors hold more relations-based interactions with the case subsidiaries than the lower-tier ones did. Moreover, unlike the reliance on informal relations suggested by extant literature on doing business in emerging economies, it is found that the economic governance mechanisms based on distributor performance have been predominantly adopted by the case subsidiaries. Thirdly, by investigating how the complementary resources are transferred to the subsidiaries, this work discovers EMNEs’ weakness at responding to the host market-oriented subsidiary transformation in terms of resource deployment within MNEs, in particular those resources that have been mostly controlled by headquarters. In addition, the term “migrating headquarters”, which represents an extreme outcome of subsidiary development, provides novel knowledge to the extant literature on the relocation of MNE headquarters by the perspective of resource circumstances. Moreover, the five components comprising dynamic capabilities in the context of subsidiary transformation are identified through the two case studies as being: capability upgrading, capability leverage, capability building, coordination capability and cooperative capability.

Taiwanese Enterprises gradually become internationalized and invest foreign markets. The thinking of business global operation is no longer on one country, but on multi-nations. Companies may have different factors of the motivation and background to foreign direct investment in different countries. Each country¡¦s culture and business environment has its uniqueness. Another reason of global industries changing is that the developing countries in the past have become new economic systems. Mostly new economic governments adopt open economic policies and encourage foreign investment. Therefore, these new economic countries are often taken into account by foreign direct investment. The purpose of this study is discussed how Taiwanese enterprises determine their entry mode in India market. This study is built the framework under three dimensions which are environment, strategy and resource. For the moment, there are around 28 Taiwanese enterprises have invested in India market. This study is analyzed Taiwanese cases by questionnaire survey, telephone and in-person interviews to understand the import factors of entry modes in India market for Taiwanese enterprises. Research data analysis is strengthened by qualitative discussion and enhanced research reliabilities through both case studies and questionnaire surveys. The question items and study framework are designed from the cases of Taiwanese enterprises and industrial experts¡¦ opinions. It is found in this study that Taiwanese enterprises tend to adopt greenfield strategy as entry mode to India market from the perspectives of environment, strategy, and resource. However, if the purpose of foreign investment of Taiwanese companies is to get the local market, they will tend to adopt joint-venture as entry mode. Finally, the study is to explore entry mode in India market for Taiwanese enterprises based on the strategic perspectives to have an integrated analysis. This makes contributions to who are willing to invest in India market.

Taiwanese small and medium enterprises always hold an important role in leading the Taiwanese economic to develop in globalization, creating many job opportunities in the country as the foundation for the social and political stability. But by the trend of worldwide business merging and expanding enterprises scale, small and medium enterprises in Taiwan have to face challenges of upgrading and changing the type of business. To be able to survive and grow, Taiwanese small and medium enterprises must modify their structure, improve technology, conduct automation, even to invest in less developing countries or lower-wage countries such as China and other countries in the region. Since 1988, Vietnam has become a strongly attracting investment destination to Taiwanese small and medium enterprises. Taiwan always leads in the top 3 investors in fields of number of investment projects as well as total investment capital. So the question is why so many Taiwanese enterprises choose Vietnam as an investing destination but not other countries in the Southeast Asian region? Questions such as what advantages and strengths in the Vietnamese investment environment are, what conveniences that they bring to Taiwan businesses, etc ... has become the most attractive themes in Taiwanese corps. This study used case-studied approach, combining direct observation methods to conduct data collection then analyzed to understand the motivation for investment in Vietnamese, investment state and competitive advantages of Taiwanese small and medium enterprises in Vietnam.

隨著中國大陸近十餘年來的改革開放，以低廉的勞工與土地成本、及高度持續之經濟成長，吸引台商紛紛將過去的台灣經驗移植到大陸。本研究從大陸子公司角度探討影響其經營績效之因素，分析台商母公司的智慧資本對大陸子公司經營績效的影響，特別將母子公司間的移轉機制與子公司的吸收能耐納入實證分析中。 本研究採用田野研究、問卷調查、與實證資料檢定，並結合多種不同的資料庫來源，以在大陸設有子公司進行投資活動之我國公司為研究對象進行問卷調查，回收之有效樣本合計共103家。路徑分析之結果發現大部分台商母公司所擁有的智慧資本會直接影響大陸子公司的經營績效。在智慧資本的移轉成效上，台商人力資本有移轉和吸收效果，但創新資本的效果則不佳。在上市櫃電子業之樣本下，母公司所擁有的人力資本係先透過影響母子公司間的移轉機制，再間接影響大陸子公司的資產報酬率。當台商母公司所擁有的人力資本愈高時，有助於提高大陸子公司之吸收能耐，並間接影響大陸子公司的資產報酬率。另外，迴歸分析之結果發現，不同智慧資本組成要素對大陸子公司經營績效影響的程度並不相同，人力資本對經營績效有顯著的正效果，而創新資本對經營績效的影響並不顯著。本研究最後建議理論或實務上之管理意涵。 / Over the past decade, the regulations of China have changed, and it provided a huge resource of cheap labor and land. Following the rapid economic growth has attracted Taiwanese enterprises to transfer their success experiences to China. It is important to examine the determinants of performance of subsidiary in China. This study analyzes the relationship between intellectual capital and performance covering the transfer from Taiwanese parent to Chinese subsidiary. This study particularly highlights the role of transfer mechanism and absorptive capacity in explaining the effect of intellectual capital on performance. This study integrates multiple research methodologies including field study, questionnaire, and empirical study. Since no single database exists to support this study, multiple sources are employed for constructing the sample frame. Based on a sample of 103 subsidiaries of Taiwanese enterprises in China, results of path analysis indicate that intellectual capital from parent is positively associated with the performance of subsidiary. In general, the results support that the effects of human capital on performance are mediated by both transfer mechanism and absorptive capacity, but the transfer roles of innovation capital are not supported. Finding from the public electronic industry reveals that the influence of human capital on return of assets is indirect through the mediating role of transfer mechanism. An absorptive capacity path is presented where absorptive capacity is associated with return of assets, and human capital influences absorptive capacity. Moreover, regression analyses demonstrate that different intellectual capital elements have a different effect on organizational performance. Human capital is important in explaining the variations in the performance of subsidiary, while innovation capital has little or no effect. Implications for theory and research are discussed.

台灣的經濟主要以外銷為導向，近年來因為中國大陸經濟崛起，隨著兩岸經濟的逐漸開放，供應商產業外移，無論傳統產業或高科技產業製造相關企業，西進中國大陸已成台灣產業發展主流，貿易商採用多角貿易進行各種不同商業活動方式早已發展為台灣企業從事國際多角貿易的交易模式，而現行稅務主管機關對傳統外銷之各項租稅規定、法令規範、稽徵程序、實務審核作業規範等，對於台灣產業國際多角貿易類型，產生許多租稅疑義。因此，本論文以問卷調查方法，探討台灣企業從事國際多角貿易面臨之租稅相關議題，以提出改進我國企業從事國際多角貿易之相關租稅規範建議，供政府主管機關參考。 　　本文的問卷結果顯示，國際多角貿易之營業比重在台灣產業已占有舉足輕重之地位，且超過50%受訪企業認為，公司從事國際多角貿易交易與傳統直接外銷，不論在經濟實質、權利義務或風險瑕疵責任歸屬，兩者均相同。有70%以上之受訪企業表示對現行加值型營業稅及營利事業所得稅，在適用上產生困擾。雖然，現行法令對於公司從事國際多角貿易交易收入有銷貨及勞務之區分，但本文的問卷結果顯示有超過80%以上受訪企業認為企業從事國際多角貿易交易的性質係屬銷貨行為，並希望財政部簡化現行對國際多角貿易交易之課稅規範。 　　本論文建議，要健全國際多角貿易課稅規範，消弭國際多角貿易之租稅疑議，首先，必須打破現行課稅法令對國際多角貿易區分由國內出貨或第三地出貨，依出貨地是否在中華民國境內而有不同認定之迷失。其次，對國際多角貿易之會計處理應回歸交易實質，不應藉由課稅之考量來左右會計基礎之入帳原則。最後，財政部應簡化現行對國際多角貿易之課稅規範，減少企業因複雜之課稅規定而將第三地出貨之多角貿易收入規避不列入台灣之營業收入。 / Taiwan's economy is primarily export-oriented. In recent years, because of the rise of economy in mainland China, with cross-strait economy liberalization and relocation of suppliers, both traditional and high technology industry businesses have been moving to mainland China as mainstream of Taiwan's industrial development. Multi-lateral transactions have been adopted by Taiwanese companies in engaging in various international business activities. However, tax laws and regulations, as well as assessment procedures adopted by Taiwan tax authorities, on multi-lateral business have triggered many tax disputes. Therefore, with surveys by questionnaires, this study aims to investigate into the relevant tax issues in the multi-lateral international trade of Taiwanese enterprises and propose suggestions for the tax authorities to improve Taiwan tax treatment on multi-lateral international trade. 　　The questionnaire results show that multi-lateral international trade has become a dominant business model in Taiwan industry, more than 50% of the respondents consider both multi-lateral international trade transactions and the traditional direct export are the same, with respect to economic substance, rights and obligations or liability risks of the transactions. More than 70% of the respondents indicate that they have encountered problems when applying to the existing value-added tax law and business income tax law. Although the existing reguations for companies engaging in multi-lateral international trade transactions classify such transactions into sales and services in their respective tax treatments, the questionnaire results show that more than 80% of the respondents consider such transactions should be all regarded as sales of goods, and urge the Ministry of Finance to simplify the existing taxation on such transactions. 　　This paper proposes the following suggestions to make taxation on multi-lateral international transactions more reasonable and enforceable. First of all, the existing taxation on multi-lateral international trade should not classify such transactions as domestic shipment or third place shipment solely by whether the shipping point is in the territory of Republic of China or not. Second, the accounting for international multi-lateral trade should reflect the substance of such transactions instead of following the tax law treatment. Third, the Ministry of Finance should simplify the existing tax treatment for multi-lateral international trade to prevent Taiwanese enterprises from under-reporting multi-lateral international trade revenues derived from third place shipment in filing Taiwan business income tax because of the complexity of the exitng tax regulations.