由于众所周知的历史原因,台湾地区与祖国大陆分离了半个多世纪。同属于一个中国的海峡两岸的收养法律制度有着共同的渊源,即深受中华民族源远流长的古代收养制度的影响。但是,由于海峡两岸属于不同的法域,在收养关系方面存在法律冲突是不可避免的。从半个多世纪的发展来看,台湾地区与祖国大陆在社会性质、政治制度、经济体制乃至法律制度等多方面存在不少的差异。因此有必要对海峡两岸收养关系进行对比研究,并在分析海峡两岸收养关系成立主要冲突的基础上,提出解决的方案。 For well-known historical reasons, Taiwan has been separated from the mother mainland for more than half a century. The law of adoption adopted by both sides of the Taiwan Strait belonging to one China has a common origin, namely being influenced by the ancient adoption system that has a long history of the Chinese nation. However, due to the fact that both sides of the Taiwan Strait belong to different jurisdictions, the existence of a legal conflict in the adoption of relations is inevitable. Judging from the development of more than half a century, there are quite a few differences between the Taiwan area and the mainland of the motherland in many aspects such as the nature of society, the political system, the economic system and even the legal system. Therefore, it is necessary to conduct a comparative study of the adoption of cross-Strait relations and to propose solutions based on the analysis of the major conflicts that have arisen between the adoption of cross-Strait relations.