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The cash dividend payout ratio in Taiwan had declined slowly in past years, but it suddenly became higher and higher since 1998. The phenomenon gave me the motivation to try to find the reason why the trend of cash dividend payout ratio changed the direction. I first test the relationship between the characters of firms and their cash dividend payout ratios. The results declared that the market-to-book ratio, earning ability and firm size significantly influences the cash dividend payout ratio. Then I tried to test the catering theory to recognize if the change of cash dividend payout ratio trend can attribute to managers¡¦ desire to cater the demand of investors and found catering theory seems capable in explaining the phenomenon. But Hoberg and Prabhala (2007) indicated that if we take the risks into account, the catering theory can not sufficiently explain the change of the trend of cash dividend payout ratio. So I took Tax Integration and the risks which calculated by the methods of Fama and French (2003) into account to prove their perspectives. At last, the results revealed that the influence of catering were not very strong if we consider the risks of firms, but the influence of risks and Tax Integration has significantly great influences.

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過去對公司資本結構的研究可分為兩大方向，一是對資本結構理論的探討，一是對影響公司資本結構因素的探討。我國於87年對投資所得改採兩稅合一制度後，兩稅合一對公司資本結構影響的探討成為研究的主流。本研究所要探討的問題有三。第一，兩稅合一後，公司的負債融資比例是否下降；第二，兩稅合一後，有效稅率、現金股給付率和獲利率與負債比率間的交互作用情況為何；第三，不同有效稅率或公司規模對負債比率的影響。 本研究的實證結果如下： （一）兩稅合一後，公司的負債比率會下降。 （二）兩稅合一前後，有效稅率與負債比率均呈正向關係；而且兩稅合一 後，有效稅率對負債比率的影響下降。 （三）兩稅合一前後，現金股利給付率與負債比率均呈反向關係；而且兩 稅合一後，現金股利給付率對負債比率的影響下降。 （四）兩稅合一前後，獲利率和負債比率均呈反向關係；而且兩稅合一 後，獲利率對負債比率的影響上升。 （五）兩稅合一之後，原有效稅率較高之公司的負債比率下降程度較多， 而原有效稅率較低之公司的負債比率下降程度較少。 （六）兩稅合一之後，原規模較大之公司的負債比率下降程度較少，而原 規模較小之公司的負債比率下降程度較多。 / The past researches on corporate financing structure can be divided into two lines, one in the corporate financing theories and the other in the determinants of corporate financing decisions. After the tax integration, the research whether the adoption of tax integration has a significant impact on corporate financing structure have become a mainstream. The study investigates three issues. The first is to investigate whether the debt ratio decreases after tax integration. The second is to investigate the effect of effective tax ratio, dividend payout ratio, profitability on the debt ratio. The third is to investigate whether the effect of tax regime change on the debt ratio is difference between effective tax ratio and firm size. The empirical results show follows: (1) After tax integration, the firm’s debt ratio decreased. (2) Effective tax ratio has positive relation with debt ratio no matter before or after tax integration. After tax integration, the degree of effective tax ratio effect on debt ratio declined. (3) Dividend payout ratio has negative relation with debt ratio no matter before or after tax integration. After tax integration, the degree of dividend payout ratio effect on debt ratio declined. (4) Profit ratio has negative relation with debt ratio no matter before or after tax integration. After tax integration, the degree of profit ratio effect on debt ratio increased. (5) After tax integration, the decline of debt ratio for company with higher debt ratio is more than the decline of debt ratio for company with lower debt ratio. (6) After tax integration, the decline of debt ratio for small firms is more than the decline of debt ratio for large firms.

我國於民國87年實施兩稅合一制度，為了驗證兩稅合一實施後企業投資與理財行為是否受到顯著的影響，並進而評估財稅當局實施兩稅合一是否能達成鼓勵投資與提高租稅中立性（降低企業舉債之誘因），本研究將採用台灣經濟新報資料庫的企業財報資料來進行實證研究。 有鑑於企業的新增投資與企業的負債比率兩者相互影響，若分別予以估計，則可能產生偏誤，因此本研究將影響企業投資行為方程式與影響企業負債比率方程式加以聯立，然而若只是利用傳統的最小平方法（OLS）並以聯立方程式模型（simultaneous equations model）實證，則對於企業之時間序列—橫斷面資料（以下簡稱panel data）的廠商特定效果或是不可觀察的效果仍無法消除，因此要同時考量panel data的處理與變數互為內生的問題，就必須利用聯立方程式模型來處理panel data，這也是本文主要的實證方法。 實證結果顯示兩稅合一實施後企業新增資本投資有顯著的增加，符合預期。此外就降低負債比率方面，結果顯示實施兩稅合一後企業之負債比率顯著降低。

Mainland China has implemented two sets of income taxes systems for many years. One is for the foreign enterprise “1991 Promulgated Foreign Invested Enterprise and the Foreign Enterprise Income Tax Law” and another one to the domestic enterprise, “1993 promulgated Enterprise Income Tax Temporary Regulation”. The coexisted of two taxes not only resulted in unfair taxation but also created fake foreign enterprise phenomenon. It is especially difficult for people to accept this situation after China joined the World Trade Organization. The legislation conditions matured after speedy growth of Chinese economy. The Chinese government considered the current financial situation can withstand the impact on decrease in tax revenue after new tax law implemented and it met one of the current economic development targets of “nurture domestic enterprise”. On March 16, 2007, the “Enterprise Income Tax Law of the People's Republic of China” (here in after referred it as the New Law) was eventually approved after many years of research. It surely will have profound influence on foreign enterprise including the Taiwanese businessmen. The purpose of the study is how the major changes of the New Law impacts the China investment of the Taiwanese businessmen. The structure of the study, other than abstract and conclusion, firstly, the author will discuss of the content of system and policy changes. Next, based on the major changes of the New Law, how they affect designed research method. Analyze and forecast its possible impact and influence on Taiwanese businessmen in the following categories: (1) tax incentive; (2) organization structure organization, and (3) tax risk. Finally, the author will propose the related action taken and suggestions on the impact.

The role of the Court of Justice of the European Union in the process of direct tax integration in the European Union (EU) has been widely discussed in the academic literature, while another important actor, the European Commission, has attracted much less attention. The Commission’s input is commonly perceived to be limited to the right of legislative initiative. This study questions such an oversimplified interpretation and draws a more nuanced picture of EU tax harmonisation by integrating an analysis of the complex regulatory approaches adopted by the Commission for the establishment and smooth functioning of the Internal Market. It is argued that the past decade brought a notable change in the Court-dominated pattern of direct tax integration. This change is apparent first in the evolution of enforcement strategies under Articles 258 and 260 TFEU; and second, in the increased reliance upon non-binding regulatory measures. Both developments have strengthened the role of the Commission, supplying it with more possibilities for influencing national direct tax systems, despite the reluctance of Member States to agree upon legislative harmonisation. Against this background, the procedural and substantive problems associated with these instruments require closer examination. The normative scope of this research covers the key procedural problems related to the infringement procedure and non-binding regulatory measures. The empirical component explores the Commission’s enforcement and coordination practices, drawing particular attention to two case studies: the tax treatment of losses in cross-border situations and exit taxation. Following the analysis of enforcement and coordination in the field of direct taxation, the study argues the need and proposes potential solutions for (i) the developing of a more comprehensive procedural framework for the infringement procedure and non-binding regulatory acts; (ii) the strengthening of accountability mechanisms; and (iii) the enhancing of the effectiveness of their application.