Real Estate Investment In China - Legal Review And Analysis Of Foreign Investors' Participation
| Author: |
Xiaoyang Zhang
Lecturer of Business Law, The Open University of Hong Kong
|
| Issue: |
Volume 6, Number 2 (June 1999)
|
Contents
- All land in China belongs to the state or the collectives. Foreign investors may only obtain a land use right, rather than land ownership.
Whilst in practice a particular site may exist in possession of a specific land occupier, the primary market of real estate, where
a land use right is acquired by foreign investors to develop and use the land, is ultimately monopolised by the state. Foreign investors
normally have two alternatives to obtain such a right: a) direct purchase from the state; or b) automatic acquisition as an investment
substitute contributed by the Chinese partner in an equity or co-operative joint venture.
- Trading activity conducted by foreign investors in the secondary market is defined in two different ways. Firstly, a land use right
acquired from the primary market may be further traded on the secondary market by means of transferring, leasing or mortgaging. Secondly,
incomplete property to be developed on the land obtained could be sold in advance, and by doing so funding required for the whole
construction is accumulated at least partially from the source of prospective property owners.
- Private ownership of land has been abolished in China. Under article 10 of the 1982 Constitution, urban land belongs to the state, with rural land owned by the collectives. Since the rural collectives are administratively subject
to the leadership of the central and local governments, it can be generally construed that all land ownership is commanded by the
state.
- Although private ownership of land is not available in China, article 2 of the Constitution's Amendment Act 1988 provides that a land
use right is allowed to be transferred. Under this context, a land use right becomes divisible from land ownership, thus making
it likely for the former to be privatised. Transfer of a land use right has accounted for most of the business activity in the primary
real estate market. It is actually a kind of administrative practice by the land administration authority which, on behalf of the
government, takes charge of granting permission to prospective land users who have already paid the required land transfer fees.[1]
- However, it was not until the amendment of the Constitution in 1988 that a land use system had been able to be established on a leasehold basis, which means for a fixed term. Most Chinese
organisations in the past were administratively assigned free properties for the purpose of their business use. Because of this
historical reason, a dual land use system is still operational at present. On the one hand, foreign investors have to pay for the
use of the required site. On the other hand, many local Chinese entities are in possession of the right to use and control the land
obtained free from the state, and may transfer such right to other parties or contribute them as an investment substitute in equity
or co-operative joint ventures. Although in theory the land owner, that is, the state, is entitled to claim back part of the profits
from the local entities in question, a lack of legal provisions in the existing legislation has exempted them from being asked to
do so. That is why some foreign investors, when talking about real estate business, often grumble at the current uneven footing
in competition with local counterparts.
- Unification of the dual land use system can hardly be fulfilled in a short time. Alteration of the on-going system is as a matter
of fact closely connected with the performance of the country's corporation-based enterprise reform, which first of all has to deal
with the basic issue of a state business entities' property right. This requires that state-owned organisations be conferred the
right to own and use state assets as independent business entities, with no further administrative influence being applied to them.
However, this can only be brought about by implementing a full leasehold system of all land use rights.
- The main rules regulating real estate business conducted by foreign investors are composed of two parts. First, the central government
has provided several guiding principles, most notably the Interim Rules 1990 on Sale and Transfer of State Land's Use Rights in Cities
and Towns (the 1990 Interim Rules), and the Regulations 1990 on Development and Management of Tracts of Land by Foreign Investors
(the 1990 Regulations). Secondly, local authorities have also promulgated some regional policies, oriented towards providing more
incentives to foreign investors and are only applied in particular local jurisdictions.
- The State Land Administration Bureau as the government-designated agency is the regulatory authority responsible for overall administration
of the State's land. All the land has to be registered and recorded by it. And the Bureau in turn issues a land registration certificate
for entitlement of any specific use. No right can be acquired from the primary market or further traded on the secondary market
unless the site concerned has been granted such a certificate. To obtain the right, foreign investors need to apply to the Bureau
for approval. The Bureau in this sense plays the most momentous role in regulating foreign investment activity on both the primary
and secondary market.
- According to article 13 of the 1990 Interim Rules, direct purchase of a land use right can usually be effected by means of negotiated
agreement, and public bidding or auction.
- In reality, a right transfer by means of negotiated agreement is the way most transactions relating to foreign investment are conducted.
It is the most popular form of transfer in comparison with public bidding and auction, as in the latter case the investor would
be less capable of controlling the price. The investor interested in a particular piece of land may simply approach the present
occupier (usually a local Chinese organisation) to express their wish of acquisition. In the event that an acceptable transfer fee
is arrived at, the present occupier may notify the State Land Administration Bureau of their willingness to sell. The Bureau would
then have to assess the correctness of the suggested transfer price and in some instances render adjustment to it.
- Nevertheless, negotiated agreements have problems as well. Although the State Land Administration Bureau has from time to time formulated
rules capping the permissible lower price limit, many local entities in practice still compete with each other by slashing land prices,
attracting more influx of foreign funds. However, this problem could hardly be resolved in the short term because of the diversity
of land supply and more understandably the urgent need for absorbing investment from overseas.
- In order to protect foreign investors' interests as well as the state coffers from further suffering, encouragement of adopting public
bidding and auction is particularly recommendable in future practice. The form of negotiated agreement may continue to exist, but
ought to be tailored for and confined to the less popular land.
- Direct purchase of a land use right is subject to the terms of the purchasing contract completed between the purchaser (that is, the
investor) and the local branch of the State Land Administration Bureau. It must also comply in a well-balanced manner with the requirement
of the state's overall urban and rural development and construction plan.
- The duration of a land use right is determined by the actual nature of the project to be undertaken. According to the 1990 Interim
Rules, the investor should within the terms of the land use stipulated in the contract carry out the intended development programme,
and any operational delay will result in the government's withdrawal of the right already acquired (article 17). In the event that
the investor wishes to continue their operation on the land after the term of its use expires, renewal of the right is possible (article
41), provided that the total terms added together do not exceed the maximum permissible length of time. Article 1[2]
sets forth various maximum terms, that is, seventy years for residential buildings, fifty years for industrial use, fifty years for
the purposes of education, science, technology, health, and sports, forty years for commercial and recreational use and also for
the tourist industry, and fifty years for other uses. In practice the above maximum terms are provided only as general guidelines.
Many local authorities have formulated rules different from the above and applied only to their own jurisdictions. However, the
overall tendency is that the maximum term of a land use right is becoming more dependent on the type of property to be developed.
To cool the present overheated, haphazard luxury property market, the government is now working on readjusting investment structures
by strictly refraining foreign investors from developing luxury estates for recreational and tourist purposes.[2]
Investors are instead strongly encouraged to develop properties for ordinary residential use.
- In principle, application for a land use right ought to be based on one or more 'concrete' development projects. Therefore, the permissible
business scope is limited to the activities closely connected with the fulfilment of the specific purpose identified in the purchasing
contract. The investor is required to proceed the construction within the confines of the land use (article 17 of the 1990 Interim
Rules), and may not arbitrarily use the land for other irrelevant purposes. Some experts suggest that the investor should be committed
to a development expenditure of not less than 25% of the land purchasing cost and this commitment must be really implemented on the
land in the first post-purchase year, otherwise the government has the right to withdraw the land in question.[3]
Concessions may be given if the investor has changed the previous usage of the land with official sanction in advance; in such circumstances
a new purchasing contract has to be negotiated with the land use fee adjusted accordingly (article 18).
- The land use fee has to be fully paid within sixty days after the purchasing contract is completed, and any delay in full payment
may incur a termination of the deal (article 14). The investor is not entitled to use the land before being granted a land use licence,
which will not be issued until full payment of the required land use fee is made and registration with the State Land Administration
Bureau is finished (article 16). So far no standard has yet to be set forth governing the fixing of land use fees. The rate is
usually determined by classification based on the circumstances of different geographical locations, lines of business, proposed
investment volumes and usage terms. In practice, the rate for using comparable land may vary considerably. The reason is attributable
to the lack of clear legal provision as well as to the serious shortage of qualified surveying professionals. Since a land use right
in the past was obtained as a result of free administrative assignment, surveying now appears to be one of the weakest areas in China's
real estate industry. Even in the case of public bidding or auction where the price issue is less significant, how to properly fix
the rate is still a matter of great concern to foreign investors.
- The right to use tracts of land bears a special meaning under the 1990 Regulations. By virtue of article 2, after obtaining the land
use right the foreign investor will be committed to convert the existing land which has not been reclaimed into the land equipped
with basic infrastructure facilities ready for further industrial or commercial development. Also in the context of this article
the investor can transfer or rent out the reclaimed land to other parties after the required infrastructure facilities are formed
and meet the necessary criteria made by the relevant authorities.
- Acquisition of the right to use tracts of land enables the foreign investor to administer the land for their own benefit. They have
more freedom to control the land by either retaining it for further appreciation, or getting rid of it at the appropriate time.
To the Chinese government, absorption of foreign investment in this way incurs no increase of the state's fiscal burden. Instead,
development of infrastructure facilities could be accelerated by utilising foreign money; the government alone has no financial ability
to do this.
- To carry out the reclamation programme, the developer is required to act in the capacity of either an equity joint venture company,
or a co-operative joint venture, or a wholly foreign-owned enterprise (article 4). Therefore, it is necessary for the foreign investor
in question to select and establish their tailor-made investment vehicle in the first place.
- A Land use right could be automatically acquired by the foreign investor in the case of an equity or a co-operative joint venture,
where the Chinese side supplies the land as an investment contribution. If this happens, no matter if the Chinese side is in possession
of the land at the time or obtains the land by indirectly leasing it from a third party, the joint venture on the whole no longer
needs to pay any land usage fee to the government. That is to say, the overseas side in either event is automatically entitled to
use the land contributed by the Chinese.
- The origin of the legal basis of automatic acquisition lies in the Law on Joint Ventures Using Chinese and Foreign Investment of 1979,
that is, the 1979 Law governing equity joint ventures and its 1983 Implementing Rules, and also the Law on Co-operative Joint Ventures
of 1988, that is, the 1988 Law.
- Pursuant to the 1979 Law, in an equity joint venture, investment contribution from the Chinese side may include a land use right (article
5). Such stipulation is then further supplemented by the 1983 Implementing Rules which state that the value of the right contributed
has to be equivalent to the usage fee paid for obtaining the land of similar quality (article 48). In such event, both the foreign
and Chinese investor could enjoy the privilege of maintaining the land as the common asset of the joint venture. To the foreign
side, they are automatically entitled to the right of land usage without being involved in any direct purchasing or leasing. As
such, no additional cost has to be borne by them. Moreover, the right as an investment in kind is valued by the relevant appraisal
authority, and by virtue of article 51 such valuation after the first appraisal remains unchanged during the company's whole operation
term. The foreign investor therefore may plan and hedge against overall future outlay in a more effective way. To the Chinese side,
advantage could be taken of from the right as an appropriate vehicle for attracting overseas capital, in addition to sharing future
profit in line with capital proportions contributed in the joint venture. Since the land submitted in such a way was normally in
the previous possession of the Chinese party on a free allocation basis, investment of a land use right is especially suitable for
the Chinese side to solve the problem of inadequate funding required for cash capital contributions.
- The 1988 Law accepts, under article 8, that a land use right may be counted as an investment contribution by the participant(s) in
a co-operative joint venture. However, the right is not valued in the same way as in an equity joint venture. Contrary to the latter,
in which each side must bear the risk and share the profit in proportion to its capital contribution, both overseas and Chinese participants
in a co-operative joint venture are legally bound on a contractual basis and have to co-operate as separate legal entities. Investment
contributions, risk responsibility and profit distributions are specified on the contract in advance. Therefore, the Chinese side
is rewarded according to the terms of the contract, and may not necessarily share the risk and profit strictly in accordance with
its investment proportion. In this instance, the right is contributed as a contractual arrangement between the two sides. Since how
each side is rewarded depends completely on the terms of the contract, the land use right in a co-operative joint venture does not
need to be valued in currency terms. Compared with the method used in the equity joint venture, the legal terms about automatic
acquisition of land in the co-operative appear to be more ambiguous. Such ambiguity exerts two different impacts on the interests
of investors. Firstly, the investment yield to be divided and the risk responsibility to be shared may very often in reality not
be easily defined in the contract. This is almost invariably the cause for many disputes between the two sides who gain no clear
indication from existing legal and administrative documents on how to fix each side's interests in the most precise way acceptable
to both parties. Secondly, if considered from another angle, the mode of automatic acquisition in the co-operative may have its
unique flexibility. Since the investment value of the land is not required to be assessed purely on the technical basis ruled by
the appraisal authority, it is likely that the foreign investor may find a way to orient the prospective profit allocation scheme
to be carried out in their favour more effectively.
- Regarding the automatic acquisition of land by the means of setting up an equity or co-operative joint venture, the most conspicuous
problem at the moment is rampant use of public land and non-agricultural occupation of farmland. Under such circumstances, neither
the Chinese nor the foreign side pays anything for land usage. Since foreign investment enterprises may enjoy favourable privileges
compared to domestic businesses especially in tax, many real estate equity and co-operative joint ventures are created purely for
the sake of illicit speculation, profiteering and tax evasion. Hence an interesting phenomenon occurs. At one end a huge amount
of land is left idle but monopolised by a few such enterprises with no 'concrete' development plan. At the other end, land prices
are unreasonably inflated on the market, seriously affecting the interests of honest foreign investors who abide by the land regulations,
wishing to conduct legitimate estate development.
- To regulate the above improper phenomenon, local authorities are starting to react. Unreasonable land transfer plans are being banned
resulting in a large number of unscrupulous real estate joint ventures being phased out. Furthermore, any future acquisition of
land by foreign investors must be subject to specific development programs in compliance with the prevailing investment orientation
policy.[4]
- The Chinese side is no longer allowed to provide loans aimed at assisting property development, or guarantee loans from other sources
to the overseas partner in one way or another.[5]
- Once obtained from the primary market, a land use right could be further transacted in the secondary market.
- Theoretically, re-transfer of a land use right is a civil activity, and the government normally plays a supervisory role not interfering
administratively unless really necessary. However, carrying out a re-transfer dealing has to meet certain criteria. Possession
of a land use right does not mean that the right can be immediately re-traded. Such criteria may slightly differ from one local
jurisdiction to another. However, three general conditions are to be fulfilled in the first place in order to re-transfer the right:
full payment of a land acquisition fee; possession of a land use certificate; and payment of a certain percentage, usually at least
25% of the required construction finances for developing the land obtained.[6]
- By articles 19 and 20 of the 1990 Interim Rules, a right to re-transfer has to be conducted by agreement. Usually within fifteen
days after signing the contract, the new land user will be required to re-register the status of the current right at the State Land
Administration Bureau, upon payment of the corresponding re-transfer fee.[7] All the paperwork during the process of transaction may not necessarily be notarised.[8] However, article 21 provides that the previous obligation relating to such right is not relieved, but still has to be fulfilled
by the transferee, and any alteration of the original purpose for using the land is subject to the consent granted by the Bureau.
Once the contract is implemented, the right to use the properties, if any, on the land in question will be automatically conferred
to the transferee (i.e. the new land user) (article 23). Nonetheless, the transferee's entitlement does not cover the entire term
of a land use right previously decided. It is calculated on the basis of the previous term less the time already used by the transferor
(article 22).
- The government normally does not interfere in the re-transfer pricing. As there is no existing legal basis for determining such a
price, it is principally up to the concerned transferor and transferee to decide what price is acceptable to both parties. However,
the price difference for re-transferring land of similar quality may not be unreasonably high. In the event that the re-transfer
price in question is conspicuously lower than the prevailing market price, the local government may enjoy priority in purchasing
the right (article 26). Again, foreign investors proposing a land re-transfer should ensure in the first instance that nothing lower
than 25% of the proposed investment volume is already paid up, otherwise any contract made and price decided may become invalid.
- The investor may rent out the right acquired to somebody else from whom rental income is received. In terms of article 29 of the
1990 Interim Rules, such transaction should be conducted by completion of a leasing contract between the investor who acts in the
capacity of a lessor, and the lessee who is correspondingly conferred the right to use the land. Both sides should come to the State
Land Administration Bureau to re-register the leasing transaction within twenty days after the contract comes into being.[9]
- The essence of leasing a land use right is that the lessee must carry out the development scheme in accordance with the terms and
conditions which the foreign investor has proposed and agreed to comply with while previously acquiring such right. This illustrates
that the leasing transaction concerned incurs no re-transfer of a land use right in a legal sense.
- During the leasing period, if the investor intends to re-transfer the right to a third party, such action will not affect the legal
privileges enjoyed by the lessee. The transferee in question should continue to guarantee the effectiveness of the leasing contract
signed between the investor and the lessee who is using the land at the time.
- However, the leasing transaction itself does not release the investor from any commitment of fulfilling their original obligation
for using the land concerned (article 30 of the 1990 Interim Rules). They must make sure that the land continues to be utilised
pursuant to the previous plan, and that the fixed objective thereof can be achieved on time.
- It is likely that the foreign investor may raise mortgages on an acquired land use right from the local financial institution to which
they have mortgaged the land use certificate for the loan required.
- A mortgage transaction is normally preceded by set-up of a mortgage contract between the investor and the lending institution. Within
fifteen days after completing the contract, the parties concerned shall register at the State Land Administration Bureau for such
mortgage.[10] When the contract term becomes due, if the lending institution is fully re-paid, the mortgage registration previously made will be
cancelled (article 38 of the 1990 Interim Rules). However, in the event that the investor fails to pay off the loan, the lending
institution may thus have to re-register the usage right in the capacity of the land's new user.[11]
- Mortgage, as a form of real security against a loan, has not been fully made use of in China for raising real estate finance. Few
references to this regard can be found from the existing legal documents, and its daily operation is subject to the administrative
instructions made by various local authorities and may differ from time to time according to the prevailing financial policy.
- The current situation is that it is still difficult for foreign investors to borrow from local lenders and use them to facilitate
the real estate investment conducted in China. Foreign investors are supposed to be the source of funds for domestic markets, and
not expected to become the borrowers of Chinese money. To prevent the economy from being overheated and also restrain further influence
from the existing inflation pressure, the government may opt to tighten the bank credit at any appropriate time. Such retrenchment
action if taken will to a large extent reduce the possibility of fund-raising from domestic sources by foreign investors in the form
of mortgaging their land use right.
- Properties may under certain circumstances be sold in advance before their actual development is fully completed.
- The types of houses in China can now be classified into two categories by virtue of different kinds of user.
- First, houses purchased in Chinese currency by domestic people are called "commercial residential houses". Foreign investors may
invest in them; whilst in reality most investors are reluctant to do so because of their low margin. Also, some local authorities
even prescribe that ceiling prices should be fixed for any commercial residential houses to be sold,[12] and this in turn further hinders the initiative of foreign investors.
- Second, houses specifically tailored as living or office accommodation for foreigners or well-earning Chinese, usually purchased in
hard currency are known as "houses allowed to be sold to foreigners". In practice, these are the houses most common to foreign investors,
as they are allowed to be sold to them in advance.
- To pre-sell the above-mentioned properties, one condition must be fulfilled in the first place. The estate developer in question
should be able to deal with matters in connection with foreign exchange payments. Foreign investors having acquired the land use
right in a foreign exchange may have little difficulty in this regard, and could start selling the properties at the very early development
stage.
- There are a number of ways of payment available to prospective purchasers in connection with a pre-development sale: a) once-and-for-all
payment; b) payment by installment; and c) payment by mortgaged bank loans.
- The biggest advantage of a once-and-for-all payment to a foreign investor is that they may rapidly accumulate the construction finance
needed for property development in advance from prospective property owners. And once the payment is effected, the potential danger
of financial risks before properties are fully built up can therefore be greatly reduced. However, the once-and-for-all payment
method has a serious downside. Profit margins are very likely to be reduced since the investor normally has to provide some discount
to attract house buyers. There would be no point for house buyers to accept such a mode of payment if they could not get big savings
by paying in full at the outset.
- In contrast to the once-and-for-all payment method, financing facilities pale to the investor in the case of payment by installments.
But to avoid the possible market risks as well as to spread the acquisition expenditure, many property purchasers may prefer the
payment by installment at the cost of failing to receive some savings. This in a way provides a relatively stable source of market
demand to the investor.
- If mortgaged loans are accessible from financial institutions, such types of payment will be very popular among customers. If this
happens, the loan arranged will normally not cover the whole purchase price, but a certain percentage of it. The buyer will be required
to pay an initial deposit (for example, 10%) to obtain a purchasing option which can be further traded afterwards at their disposal
depending on changes in market situation.[13] It is not an easy thing in practice to prod financial institutions to render mortgaged loans on houses sold on a forward trading
basis. Mortgaged loans can rarely be optimistically expected from domestic sources. Chinese institutions are very cautious in delivering
their limited foreign exchange resources on real estate business. Overseas financial institutions also take a very conservative attitude.
Firstly, they need to have a thorough understanding of the investment project with special attention paid to the properties' geographical
location, the anticipated market demand for such estates and also the potential risks likely to hamper the development in question.
Secondly, they have to make sure that all the necessary legal documents including various approval certificates issued by the governmental
organisations are ready and complete. Thirdly, since settlement in foreign exchange at different stages may present problems, only
those who are familiar with the way the Chinese financial system operates could have interests in providing such loans. In practice,
only foreign financial institutions headquartered or having branches in China may find it technically feasible to deal with such
lending business.
- Foreign investors contemplating forward sales of properties are governed under different regional policies made by various local property
administration authorities. Contrary to the State Land Administration Bureau regulating the land market, the property administration
authorities are specifically responsible for supervising trading activities regarding completed properties on the land.
- To apply to carry out such a transaction with the relevant local property administration authority, the investor should first of all
satisfy a number of conditions, including: a) they must have paid off the land use fee, and also paid at least 25% of the intended
investment volume; b) the land use certificate has been obtained from the State Land Administration Bureau, the land development
permit has been acquired from the local construction administration authority, and the sales permit has been issued by the local
property administration authority; c) the concrete sales proposal has been made; and d) the relevant supervising authorities, such
as accountants and banks, and their supervision plans have been ascertained in due course.[14]
- Out of the above conditions, the most important one is the minimum requirement of contributed capital to be paid up. The purpose
of such requirement is to prevent the investor as developer from purely occupying land for further trading, thus safeguarding the
interests of prospective property buyers. Moreover, to further regulate pre-development sales, some local authorities have taken
measures by introducing a system of a forward trading permit.[15]
- In this context, the investor must satisfy the property administration authority by providing the capital examination reports made
by the bank or the registered accountant,[16] otherwise their application for carrying out the forward selling may not be easily approved.
- A pre-development sale of property is an important reason for the formation of a "soap bubble" economy in a real estate market. However,
its speculative nature may in a way appeal to potential customers whose participation in turn boosts the liquidity and briskness
of the market. This is why the property administration authorities do not simply cancel the transactions but enforce strict control
upon them.
- China's real estate market is neither a foreign investor's paradise or hell.
- Property development could achieve good results in China due to a large potential demand. China expects to build more than 300 million
square metres of housing in urban areas, and more than 650 million square metres in the countryside.[17] Urban housing construction is anticipated to account for about 4 per cent of the country's GDP in the years to come.[18] Investing in real estate is therefore being thrown up for satisfying a GDP growth target exerting a significantly special implication.
- However, there are problems on several fronts in the arena of real estate investment in China. Firstly, a lot of uncertainties in
relation to property matters are not clear. There has been little real estate law developed so far, making foreign investors unsure
of how to weigh up China's long-term market, thus greatly hindering property development from becoming a solid industry there. To
maintain a healthy real estate business, a comprehensive body of legislation becomes compulsory. Secondly, the purchasing power
of ordinary Chinese is still weak. In Beijing for example, more than half of Beijing families do not have the ability to provide
down payments higher than RMB 30,000 (about US$ 3,600) for property.[19] This implies a rather dim prospect of profit margins in real estate investment at the moment. Such a situation might exist for a
considerable length of time, and could even deteriorate under the current Asian economic downturn. Thirdly, difficulty in financing
remains a headache. A matured mortgage system is yet in place, subject to the interconnectedness of a pool of decisive elements -
speed of recovery from the regional financial contagion, performance of the country's financial restructuring, and pace of further
opening up of the real estate market.
- Again, to foreign investors, irrational exuberance and gloom should both be averted. The real estate market in China is worth being
tapped into. Just go in with eyes wide open.
[1] Zhou, Q., Zhao, C., "Operation of Real Estate Business", China Political and Legal Studies University Press, 1993, p. 4.
[2] People's Daily (Overseas Edition), "Seven Points of Opinions in regards of Strengthening the Regulation of Real Estate Market Raised
by the Ministry of Construction, the State Land Administration Bureau, the State Administration of Industry and Commerce, and the
State Taxation Bureau", 14 August 1993.
[3] Ibid.
[4] Ibid.
[5] Ibid.
[6] Mai, Z. J., "Investing in China's Real Estate Industry", Commerce Press, 1992, pp. 211, 300.
[7] Ibid, p. 81.
[8] Zhou, Q., Zhao, C., "Operation of Real Estate Business", China Political and Legal Studies University Press, 1993, p. 23.
[9] Mai, Z. J., "Investing in China's Real Estate Industry", Commerce Press, 1992, p. 92.
[10] Ibid, p. 93.
[11] Ibid.
[12] Wen Wei Daily (Overseas Edition), "Beijing is Taking Action to Prevent Property Profiteering and Carry out the Ceiling Pricing System
for the Residential Estates", 3 November 1994.
[13] Zhou, Q., Zhao, C., "Operation of Real Estate Business", China Political and Legal Studies University Press, 1993, p. 91.
[14] Ibid, pp. 7, 8.
[15] Wen Wei Daily (Overseas Edition), "Beijing is Taking Action to Prevent Property Profiteering and Carry out the Ceiling Pricing System
for the Residential Estates", 3 November 1994.
[16] Zhou, Q., Zhao, C., "Operation of Real Estate Business", China Political and Legal Studies University Press, 1993, pp. 7, 8.
[17] China Daily (Overseas Edition), "Housing Boom to Help Spur Growth", 18 Nov. 1998.
[18] Ibid.
[19] Ta Kung Pao, "More than Half Families in Beijing Cannot Afford Higher than RMB 30,000 for House Purchase", Feb. 1999.
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