本論文就印尼、中國與新加坡的外國直接投資策略提出比較法制之批判分析，蓋2020年10月印尼在多年來致力於吸引外國直接投資未果後，提出了促進就業綜合法案(the Omnibus Law on Job Creation)取代了79項投資法令，然而結果卻是引發了法律爭議與群眾示威。本論文著眼於中國與新加坡吸引外資之成功經驗，探討其取得該等成就之原因與方法，企求為印尼找尋一個成功的吸引外資模式，取代或修正現行之促進就業綜合法模式。 This thesis offers a comparative legal and critical analysis of the Foreign Direct Investment Regulation (FDI) and strategies of attracting FDI in Indonesia, China and Singapore. Indonesia has been striving to attract FDI, and therefore on October 2020 Indonesia ratified the Omnibus Law on Job Creation replacing 79 acts regarding investment. Nevertheless, this law has raised legal controversies and public protests. This thesis focuses finding a model of FDI attraction for Indonesia through lessons learned from China and Singapore in terms of how to attract FDI. Both countries have made remarkable FDI accomplishment through their own ways. This thesis aims to deplore the reasons for the accomplishment, intending to find a better model for Indonesia than the Omnibus Law currently adopted. This thesis argues that Indonesia should reconsider the Omnibus Law approach by referring to the lessons learned from the experience of China and Singapore’s success in attracting FDI.
