Economic growth has virtually dropped to depression era levels in recent years as the domestic economy was and is still being impacted by severe competition in the international market. With the competition in the markets of most industries, how can we deal with the different stressful challenges to gain a dominant position in regard to competitiveness? There are numerous factors preventing many domestic traditional industries from being transformed, such as: the lack of innovative technical knowledge and competence, the limited necessary funds for manpower and equipment, the restriction of our government¡¦s subsidy clauses, etc. Accordingly, industry holders still keep and run their existing traditional industries, thereby raising obstacles to the promotion of the regional innovative system. The key point to solve the problem is to raise the knowledge technology level for the regional industry clusters. How can our government¡¦s policy help to assist the related industries to form the clusters and practice regional balanced development? The goal is to raise innovation in the necessary technologies; only then can an enterprise¡¦s business be sustained. According to the above, industry clusters constitute an important key to promote industrial development. The regional innovative system emphasizes the reactions and flow among organizations, including government, academia, research organizations, intermediaries, the financial market, the information network, etc. The thriving growth in the domestic economy relies much on the strengthening of innovation policies regarding urban areas. This research will discuss Chinese, Japanese and Korean governments¡¦ achievements in regard to the policies concerning regional innovations and management. The aims of the discussion include the following: 1. Investigating these 3 governments¡¦ successful cases of their innovation policies and strategies of industry clusters, in order to offer the greater Kaohsiung area a reference for practicing an innovative system; 2. Applying the results of the successful cases as suggestions for domestic traditional industries; and 3. Through integrated comparisons and analysis, substantial suggestions and measures for future development are proposed for the interaction between industry and academia, the enforcement of the administrative management regulations of the central and regional governments, the clustering strategies, etc. In addition, new energy, new materials and high technology industries are advised as a direction for the overall industrial development in the greater Kaohsiung area. Finally, the issues of industrial pollution of the environment, increasing the employment opportunities, and the cross-region and cross-nation innovative interactions are also explored.

Recent studies have reported that open-end fund has its performance persistence. However, those studies didn¡¦t mention the factors of performance persistence. Therefore, investors knows the character of the types of fund, but unable to determine which individual fund have the character given the type of fund. The main purpose of this study is to provide investors a new way to select funds. First, investors can select high performance funds in the past period and aim to pick the individual funds which fit the character of high performance persistence. This study is divided into two parts. In first part, the researcher use Spearman's Rank Correlation Coefficient Test to examine the existence of performance persistence. In second part, the study aims to use Panel Data Analysis to examine the impact of 10 factors on the performance persistence in different type of funds, and periods. Samples in the study are chosen from 160 Taiwan open-end equity funds during 2004-2011. The return rate data is rolling data. In order to remove the difference of the risks of the funds, simple return rates were transferred into Jensen¡¦s Alpha. The conclusions are shown as below¡G 1. In short term, Time of Establishment often has a positive effect on fund performance persistence. 2. In short term, Net Asset Value often has a negative effect on fund performance persistence. In long term, net asset value often has a positive effect on fund performance persistence. 3. In short and middle term, Average Investment Amount always has a positive effect on fund performance persistence. 4. Almost in all type of funds and all periods, Stock Holding Rate has a negative effect on fund performance persistence. 5. Almost in all type of funds and all periods, The Score of Monitoring indicator has a negative effect on fund performance persistence.

This dissertation uses ¡§marine good governance¡¨ as the core to discuss the establishment of marine protected areas institutions in Taiwan. As a marine nation, it is a fatal key whether Taiwan can properly manage marine resources or not. Appropriately dealing with marine-related affairs can bring success to overall national development. The marine environmental diversity makes its affairs much more complicated than the land area. The global cognition of marine management has greatly changed. ¡§The concept of public management¡¨ has shifted from ¡§government¡¨ to ¡§governance¡¨. Good governance is the aim of public management nowadays. A marine nation should aim to have good marine governance. Establishing integrated marine institutions would be the key point. Although the quantity of Taiwan¡¦s marine protected areas has greatly increased, the effectiveness of management on marine protected areas is still called into question. This dissertation recommends that Taiwan should focus on integrating the institutions on marine protected areas. The future Marine Affair Organization and the corresponding marine governance legal structure would result in a ¡§Good Governance of a Marine Nation¡¨.

In Drosophila melanogaster, sex is determined at the preblastoderm stage via an Xchromosome counting mechanism. During this process embryos that carry two X chromosomes begin to develop as females while embryos with one X start the male developmental program. The Xlinked genes involved in sex determination, also called Xsignal elements (XSEs), are: sisterlessA (sisA), sisterlessB (sisB), unpaired (upd), and runt. These genes are responsible for the transcriptional activation of the master regulatory gene Sexlethal (Sxl). Expression of Sxl is initially accomplished only in females through activation of the establishment promoter SxlPe. Later in development, Sxl is transcribed in both sexes through a maintenance promoter, SxlPm, but functional Sxl protein is only produced in female flies. Since Sxl is at the top of the sex determination cascade, understanding its regulation is key to comprehend the process of sex determination. The experiments in this dissertation were designed to better understand two aspects of the sex determination mechanism: How the protein encoded by XSE element sisA interacts with SxlPe, and how the transition from regulation by SxlPe to regulation by SxlPm occurs. The sisA protein (SisA), as part of the bZIP protein family, is thought to bind to its target as a dimer, but a dimerization partner has not yet been found. This work uses knockouts and germline clones to examine interaction between sisA and three SisA partner candidates, atf4, CG16813, and CG16815. Although the evidence described here suggest that none of the three SisA partner candidates genetically interact with Sis, we cannot rule out the possibility of redundancy between the different candidate proteins. This research unravels the timing and regulation of SxlPm expression. I have shown, contrary to previous thought, that expression of SxlPe and SxlPm overlaps for a brief period. Several of the same proteins that are involved in the regulation of SxlPe, including the XSE sisB, also regulate SxlPm. This sex specific regulation leads to a sexually dimorphic pattern of activation and early expression of SxlPm. A common enhancer region was found to regulate SxlPe as well as SxlPm. These results highlight the importance of the transition between SxlPe and SxlPm for the proper establishment of sex determination and have implications for how the sex determination mechanism evolved.

The origin of festivals in Taiwan comes from the concept of ¡§community infrastructure establishment¡¨ launched by Council for Culture Affairs in 1994. ¡§Community infrastructure establishment¡¨ takes communities as target and live them up by arts and culture events in order to promote their culture industries. This concept also draws a blueprint of various kinds of festivals or activities at different time around the whole island. Arts and culture events which combine local histories, culture, industries and tourism not only revitalize local industries but also level up the entire social environment. Further more, the model of international communication and ¡§Community infrastructure establishment¡¨ will become reality through promoting such events. However, the qualities of culture events held in Taiwan these years declined due to their fancy outward displays with poor inward statements. Such phenomena reflect the rough decision-marking process and no interaction with communities. When the financial supports from government shrink year after year, what should we do to take the challenges from long-term operation of festivals as well as culture events? This case study focuses on the project of ¡§Dream Parade¡¨ in Hsichih, Taipei county, and compare it with the ¡§Fremont Solstice Parade¡¨ in U.S., ¡§Hsinkang International Community Festival¡¨ in Chayi county, and ¡§Utopia¡¨ in Taichung city. Through analyzing these three cases, we can find two major characteristics that make the ¡§Dream Parade¡¨ an adaptable model. First, it follows the concept of ¡§Community infrastructure establishment¡¨ and accomplishes it by stepping in community with arts and culture as well as developing an interface for all residences. Second, the administration from enterprises takes place of government fund and takes the leading role to enlarge community participation. The researcher of this study also participated in the project of ¡§Dream Parade¡¨ as program specialist and tried to set up a model for running international festivals associates with local communities. The actual experience derives the following conclusion: tracing back to the original meaning of ¡§community¡¨ and regarding communities as the most important part of the model mentioned above, the operation of festivals will truly become the way to connect the international society.

<p>The European Union (EU) is built on the principle of freedom of establishment, meaning that companies have the possibility to establish themselves as a company or by setting up a secondary establishment in other Member States. This right has been confirmed by the European Court of Justice through case law.</p><p>A basic feature in domestic tax legislation is that losses are allowed to be set off against profits when calculating the tax liability of a company. At the moment cross-border loss compensation within the EU is restricted, unfeasible or just accepted on a temporary basis. This lack of recognition of loss-offset gives the fact that double taxation may occur and claims form two or more national tax systems leads to uncertainty in the way a company will be taxed. Depending on whether the secondary establishment is a subsidiary or a branch, the rules relating to loss compensation differs.</p><p>Taxation of secondary establishments is based on the principle of whether or not they are considered as a resident or a non-resident of the state. In regards to taxation of secondary establishments, the PE is considered to be a non-resident and a subsidiary considered to be a resident. However, the European Court of Justice approach of non discriminatory treatment and equal treatment that has been developed and seen in the history of case law leads to the question if the Marks & Spencer ruling that concerned secondary establishments in form of subsidiaries can be applied to permanent establishments.</p><p>The most vital difference between a subsidiary and a permanent establishment is connected to the taxation of the two. The subsidiary is considered to become a resident of the establishing state while the permanent establishment is seen as a non-resident. This legal difference between the two leads to different treatment under tax law. Taxation under a tax treaty leads to the situation where one of the contracting states will either credit or exempt the income deriving from the permanent establishment. Permanent establishments are often taxed under the method of exemption.</p><p>In the Marks & Spencer case it was held that losses and profits were two sides of the same coin. Applying this statement to permanent establishments gives the notion that if a contracting state exempts an income, there will be a set off of the symmetry of having losses and profits within the same tax system. This lead to the fact that if applying the Marks & Spencer ruling on permanent establishments that are taxed under the exemption method, allowing terminal losses to be taken into account at the head office will set off the symmetry. Therefore it can be considered as the Marks & Spencer ruling shall not apply to permanent establishments.</p>

<p>On January 1, 2010, the Swedish government changed the national rule on taxation of loans between Swedish companies and their shareholders to also comprise loans granted by foreign companies. By changing the rule to also comprise foreign companies, the government aimed to eliminate the newly discovered tax planning which is carried out by an owner establishing a holding company in another Member State from which he lends tax-free means for private consumption. These proceedings result in major tax revenue losses for Sweden since the shareholder’s income was not taxable in Sweden before the change. This change has been subject for criticism by the consultative bodies in the government bill and in the legal debate. The expression of discontent is due to the fact that the changes do not comply with the freedom of establishment. As far as is known, no one has analyzed whether this statement is correct. Therefore, this thesis aims to provide an answer to whether the changes of the rule on taxation of prohibited loans are compatible with the freedom of establishment and consequently whether the Swedish government made a mistake when changing the rule to also comprise foreign companies. Due to the freedom of establishment, it is prohibited for the Member States to take measures which restrict or make nationals refrain from establishing abroad. Intra-state loans are prohibited why they hardly ever occur and the taxation on loans therefore in practice only applies to foreign companies. Legislation in a Member State which only applies to foreign persons constitutes prohibited discrimination. Further, the high tax burden hinders nationals from taking advantage of another Member State’s more favourable legislation and makes the nationals refrain from establishing in other Member States. It is therefore considered that the rule is restrictive to the freedom of establishment. However, such a restrictive rule as in this case is justified by the aim of preventing tax avoidance taken together with the balanced allocation of taxing power between the Member States. Thus, the government makes Sweden breach EU law since the rule is not proportionate despite the justifications. The rule is too general designed since it is restrictive to all foreign undertakings and not just the holding companies with which the tax planning are performed. Further, there are other less restrictive solutions to the problem which have the same effect as the rule in question.</p>

<p>The Swedish town Kalmar suffered from economic cutbacks during the 1990’s and many local companies left the region resulting in a decrease in population. Local authorities therefore set goals of regional development and an economic turn was thought to come with foreign investments.</p><p>Fanerdun is one of the Chinese firms recently interested in investing in the Swedish market, more specifically in Kalmar. Its business idea is to build a convention centre where ap-proximately 1000 Chinese suppliers will sell light industry products to companies in the Baltic Sea region and Northern Europe.</p><p>The establishment process is of value to study since the economically strained Kalmar region managed to attract such a large investment and Fanerdun’s reasons behind its choice of location for the establishment are not apparent. The purpose of this thesis is to answer the questions why and how the convention centre was realised in Kalmar. Both given and cre-ated factors are taken into account.</p><p>To fulfil the purpose, a case study using a qualitative method with an abductive approach was used. Primary data was collected through interviews with different involved actors to give a complete picture from various perspectives. This approach is referred to as triangula-tion and was also present in the frame of reference. Three different theory fields; regional network, internationalisation and guanxi were appropriate to describe the complexity of the establishment process.</p><p>The conclusion includes the given and created factors that led to Fanerdun’s establishment in Kalmar. The given factors are; location in Europe and the Baltic Sea region, low corporate tax, low investment costs, infrastructure capabilities and small town advantage. From the analysis, created factors became clear. One common feature found to be a central factor was relationships between people, organisations and regions. From Kalmar’s perspective, the regional network anticipation explains why the establishment was realised. To answer how, the three developing regional networks; Changxing-Kalmar, Baltic Sea region and Kalmar region itself together played essential roles. From Fanerdun’s perspective, why and how Kalmar was chosen as location for its international establishment is interlinked. Different internationalisation drives were characterised by commitment, shared knowledge and mu-tual dependency between Fanerdun and Kalmar representatives. The presence of guanxi, a Chinese concept of relationship cultivation, was a specific aspect for the realisation of the convention centre.</p>

<p>Abstract</p><p>The freedom of establishment in Articles 43 and 48 EC is a fundamental freedom within the EU meaning that companies are free to set up secondary establishments in any other Member State. The freedom of establishment is an important means to achieve the com-pletion of the internal market and therefore it is important that this freedom is protected. Member States are obliged to legislate in accordance with the objectives of the fundamental freedoms, still Member States are restricting Articles 43 and 48 EC by applying discrimina-tory national legislation regarding direct taxation. In the Cadbury Schweppes judgment from September 2006 the ECJ found the British CFC legislation to be contrary to Community law. The purpose of CFC legislation is to prevent tax avoidance by conferring additional tax upon companies having subsidiaries in low tax states. According to the judgment in Cadbury Schweppes, if the CFC rules are too general in its application they are violating the freedom of establishment. Hence, the CFC legislation must be aimed specifically at “wholly artificial arrangements” aimed at circumventing national tax normally payable. Therefore it is of importance, in the context of applying CFC rules, to clarify the difference between use and abuse of freedom of establishment. It is also important to note that the CFC rules ap-ply even when a subsidiary is established outside the EU.</p><p>The concept of abuse of Community law has been developed through case law and prohib-its companies to improperly use the provisions of Community law in order to circumvent national legislation. Even if an establishment in another State is made to avoid tax in the State of origin, it is not necessarily abuse of the freedom of establishment since companies are allowed to choose to establish subsidiaries in the Member States with least restrictive rules. The ECJ stated that establishing subsidiaries with the sole purpose to benefit from the lower tax regime do not constitute an abuse of the freedom of establishment as long as the subsidiaries pursue genuine economic activity. The criteria for what is regarded as eco-nomic activity has been discussed in both value added tax and direct tax cases. The re-quirements so far is that the subsidiary established has to be physically present in the host State on a durable basis and have staff and equipment to a certain degree. The ECJ has as-sessed the criteria similarly in value added tax and direct tax cases and stated that the activ-ity has to be considered per se and without regard to its purpose or result. The activity also has to be based on objective factors and be ascertainable by third parties.</p><p>The Cadbury Schweppes case is the first case in the area of CFC legislation and the Court has provided little guidance regarding what constitutes a “wholly artificial arrangement”. As a consequence of this judgement some Member States have already changed their CFC legis-lation to comply with Community law. Nevertheless, there are cases pending before the ECJ that are further questioning the application of CFC rules and how to define a “wholly artificial arrangement”. The judgement of these cases may result in more changes in the na-tional legislation of the Member States. The future development of the difference between use and abuse of freedom of establishment is important for the protection of the principle of legal certainty. A clarification of what constitutes a “wholly artificial arrangement” will improve the foreseeability for companies and their cross-border transactions will be more efficient.</p> / <p>Sammanfattning</p><p>Etableringsfriheten i artiklarna 43 och 48 EG är en av de grundläggande friheterna inom EU som innebär att företag är fria att etablera dotterbolag i andra medlemsländer. Etable-ringsfriheten är ett viktigt medel för att uppnå målen med den gemensamma marknaden och därför är det viktigt att denna frihet respekteras. Medlemsländerna är skyldiga att lag-stifta i ljuset av de grundläggande friheterna, trots det finns diskriminerande skattelagstift-ning som strider mot artiklarna 43 och 48 EG. I Cadbury Schweppes domen från september 2006 fann EG-domstolen att de brittiska CFC reglerna strider mot gemenskapsrätten. Syf-tet med CFC regler är att förhindra skatteundandragande genom att löpande beskatta in-komster från dotterbolag etablerade i lågbeskattade länder. CFC regler som tillämpas gene-rellt är enligt Cadbury Schweppes domen i strid med etableringsfriheten. Därmed måste CFC reglerna tillämpas specifikt på ”konstlade upplägg” som har som enda syfte att undvika na-tionell skatt. Det är därför viktigt att klargöra skillnaden mellan bruk och missbruk av eta-bleringsfriheten. I detta sammanhang är det viktigt att poängtera att CFC reglerna är till-lämpliga även på dotterbolag som är etablerade i ett icke-medlemsland.</p><p>Konceptet om missbrukande av EG-rätten har utvecklats i praxis och förbjuder företag att missbruka bestämmelserna i gemenskapsrätten för att kringgå nationell lagstiftning. Även om ett dotterbolag har etablerats i ett medlemsland enbart för att utnyttja den låga skatteni-vån är det nödvändigtvis inte missbruk av etableringsfriheten eftersom företag har rätt att etablera dotterbolag i det land som är mest fördelaktigt ur skattehänseende. EG-domstolen har fastställt att etablering av dotterbolag enbart för att utnyttja en mer fördelaktig skattere-gim inte utgör missbruk av etableringsfriheten om dotterbolaget bedriver verklig ekono-misk verksamhet. Kriterierna för vad som anses utgöra verklig ekonomisk verksamhet har diskuterats i såväl mervärdesskatterättsliga som företagsskatterättsliga mål. Hittills uppställ-da krav är att det etablerade dotterbolaget måste vara varaktigt fysiskt närvarande i värdsta-ten samt till en viss grad ha personal och utrustning så att tredje part kan förvissa sig om dess ekonomiska verksamhet. Utvärderingen av den ekonomiska verksamheten måste ske självständigt utan hänsyn till dess syfte och resultat.</p><p>Cadbury Schweppes är det första målet angående CFC lagstiftning och EG-domstolen har endast tillhandahållit begränsad vägledning om vad som utgör ett ”konstlat upplägg”. Som en konsekvens av denna dom har några medlemsländer redan ändrat sin CFC lagstiftning så att den överensstämmer med EG-rätten. Icke desto mindre finns det en del oavgjorda mål som ytterligare ifrågasätter CFC reglernas tillämpning och definitionen av ”konstlade upplägg”. Avgöranden i dessa mål skulle kunna resultera i att medlemsländerna måste göra ytterligare ändringar i sin lagstiftning. Den framtida utvecklingen av vad som är skillnaden mellan bruk och missbruk av etableringsfriheten är viktig för rättssäkerheten. Ett klargö-rande om vad som utgör ett ”konstlat upplägg” kommer att öka förutsebarheten för före-tag vilket leder till en effektivisering av deras gränsöverskridande transaktioner.</p>

Manchmal habe ich Zweifel, ob ich als Wissenschaftler öffentliche Bibliotheken noch benötige. Denn die Bücher, die ich für meine Arbeiten brauche, habe ich daheim. Online-Lexika bieten Informationen kostenlos, bequem und schnell. Die Digitalisierung besorgt den Rest. Zeitschriften, von denen Bibliotheken häufig ohnehin nur einzelne Jahrgänge besitzen, sind im Internet komplett verfügbar, und selbst von gerade erst erschienenen Bücher liefern Google und Amazon inzwischen mehr als nur Inhaltsangaben. Kurz: Internet und Digitalisierung machen den „realen“ Besuch von Bibliotheken mehr und mehr überflüssig.