Institutional Comparison Of Real Estate Investment Trust

Based on a fully understand the reasons for the emergence of REITs system and thecontext of the current development through worldwide, the purpose of this paper is todefine a clear market condition and the proper legal environment for the developmentof REITs by detailed comparative study of representative REITs markets. And alsothis paper aims at exploring a REITs development model suitable for Chinese marketenvironment and legal system.This paper use comparative analysis of American REITs, S-REITs, H-REITs from thedevelopment dynamics, establishment requirements, core investment policy, taxationcriteria, and income distribution policy aspects. It can be seen that REITs system isabsorbed in income distribution policy, taxation and core investment policies.Based on all these analysis and combining with the laws and statutes of China, thispaper gives a detailed analysis of obstacles in development of REITs in China withthe current status of domestic real estate business.Then, on principle of cost minimum and controllability maximum this paper discussesthe possible pattern choice of REITs in China. This paper drives the conclusion thatChina should first develop contractual REITs based on specialized legislation. Finallythis paper put forward three policy recommendations on China's development ofREITs.