The tender offer plays an important role in the corporate takeover arena and is widely used in many countries. Taiwan established its tender offer system in 1988 by adding Artic1e 43-1 to the Securities and Exchange Act. Owing to the complex procedure and restrictions by the Taiwanese government, tender offer situations were very rare in Taiwan. Although the Taiwanese government significant1y amended its Securities and Exchange Act in 2002, tender offers are sti11 not favored by the Taiwanese enterprises. Accordingly, the current Taiwanese laws pertaining to tender offers need to be reviewed and amended on a comprehensive basis in order to create a more order1y, transparent, fair and economically efficient system in Taiwan. Since tender offer regulations in most countries choose to emulate the British or American model and the British and American tender offer systems are well-established, consideration of the British and American systems is helpful in assessing the present Taiwanese tender offer system. Therefore, this article attempts to draw lesson from the foreign experience through a comparative study. It begins with a discussion of the concept of tender offers and examines underlying principles of the regulatory approach. Then, it provides an overview of the current tender offer systems in the U.K., U.S. and Taiwan. Finally, it offers suggestions for amendments to the Taiwanese law where applicable.