一、国外反收购立法的依据 所谓上市公司的收购是指收购人通过在证券交易所或以外的合法途径.在股份转让活动中持有一个上市公司的股份达到一定比例,从而获得对该公司的实际控制权的行为。收购者最直接的目的是公司的资产、销售和市场份额的扩大。美国在20世纪80年代最为盛行的公司控制权市场理论的主要观点认为只有收购才是其中最为有 I. The Basis of Foreign Anti-Takeover Legislation The so-called acquisition of a listed company means that the purchaser, through legal means on the stock exchange or other parties, has a certain percentage of the shares of a listed company held in the share transfer activity, The actual control of the act. The most immediate purpose of the acquirer is to expand the company’s assets, sales and market share. The main point of view of the theory of the market of corporate control that was most prevalent in the United States in the 1980s was that only acquisitions were the most