Comparative law notes
業權根源 (root of title) is an English and Hong Kong law term. Regarding the latter, except in limited situations, a government lease is the ultimate root of title for properties in Hong Kong. In China, there is no equivalent concept: title to a building is conclusively proved by a 房屋所有权证 (property ownership certificate), also known as a 房产证 or 房地产证(premises permit). Separately, title to the land use rights is evidenced by a 国有土地使用权证 (state-owned land use right certificate).