At the beginning of the establishment of the company or in the process of subsequent operation, shareholders tend to enlarge the amount of the company's registered capital as much as possible based on various needs, and the corresponding shareholders' capital contribution obligations also become larger. However, based on the practical considerations of the capital contribution period and capital cost enjoyed by shareholders based on the subscribed capital system, the time when the company's registered capital is in place or the shareholders' paid-in capital is often lagging behind the actual operating needs of the company, this has triggered the moral hazard of shareholders evading the paid-in capital contribution under the condition of poor benefits from the company. Some shareholders try to leave the company through equity transfer to evade the responsibility of the capital contribution. Some shareholders simply close and cancel the company directly under the condition that the company's liabilities have not been paid off. Can the relevant operations achieve the purpose of not requiring the paid-in capital contribution and escaping legal accountability.

This paper will be combined with specific case analysis.

1. Self-liquidation stage: the subject company was established in June 2019, the shareholders are A (70% of the shares) and B (30% of the shares), and the articles of association of the subject company stipulate that "the amount of capital contribution subscribed by the shareholders shall be determined by the shareholders according to the actual business needs of the company". In November 2021, the Company held a shareholders' meeting to form a resolution on the Company's own liquidation and set up a liquidation group. In the process of liquidating the company's assets, the liquidation group found that shareholder B had not fulfilled its capital contribution obligations, and therefore sued the people's court on behalf of the subject company to request B to fulfill its capital contribution obligations. According to the subsequent identification confirmation, the subject company owes shareholder B employee claims and the existing funds are unable to pay off the debt.

2. compulsory liquidation stage: in April 2022, the people's court ruled to accept the application for compulsory liquidation filed by shareholder B. In February 2023, the case of shareholder capital contribution dispute filed by the target company obtained a first-instance judgment (at this time, the liquidation group has not yet been designated to complete). In the absence of evidence to prove that shareholder B has fulfilled its liquidation obligations, it is believed that the issue of shareholder capital contribution should be investigated in the compulsory liquidation case, and all litigation claims of the target company should be rejected accordingly.

When the liquidation group accepts the court's designation, the aforementioned shareholder capital contribution dispute case (the same below) is still in the appeal period. After preliminary investigation, the liquidation group preliminarily determines that shareholder B has not fulfilled its capital contribution obligation. Based on the principle of "res judicata", if the liquidation group does not appeal, the target company cannot claim that shareholder B shall bear the capital contribution responsibility on the grounds of unpaid capital contribution again in the future. After consulting shareholder A, shareholder A paid the opinion, the liquidation group filed an appeal in accordance with the law. In August 2023, the court of second instance rejected the appeal and upheld the original judgment on the basis that "the liquidation group has not yet approved all the creditor's rights", "the creditor who has confirmed the creditor's rights is only shareholder B", "other creditor's rights and repayment status are in a state of pending confirmation" and "the liquidation group shall claim rights on the shareholder's capital contribution responsibility after clearing and approving the creditor's and debt relationship of the target company and making clear that the target company's assets are not sufficient to repay all debts.

Combined with the above-mentioned case introduction, the author analyzes the shareholders' capital contribution obligations under different legal procedures and in different scenarios as follows:

(I) The company has not entered into liquidation proceedings (in this article, for ease of presentation, liquidation proceedings include self-liquidation, compulsory liquidation or bankruptcy liquidation proceedings, the same below), if the company is the executed person and there is a situation where the property is insufficient to pay off the debt, the shareholders' capital contribution obligation will expire at an accelerated rate.

Articles 17, 18 and 19 of the Provisions of the Supreme People's Court on Several Issues Concerning the Change and Addition of Parties in Civil Enforcement stipulate that "as a profit-making legal person subject to enforcement, the property is not sufficient to pay off the debts determined by the effective legal documents", and the executor applies for change and addition of "shareholders, investors or promoters who have not paid or not paid in full the capital contribution in accordance with the provisions of the Company Law", as well as "shareholders and contributors who have withdrawn their capital contributions", and "the original shareholders who have not fulfilled their capital contribution obligations in accordance with the law, I .e. the original shareholders who have transferred their shares or the promoters who are jointly and severally liable for the capital contribution in accordance with the provisions of the Company Law" shall be held liable in accordance with the law within the scope of the outstanding capital contribution or the withdrawal of the capital contribution, the people's court shall support. This provision is aimed at the accelerated maturity of the capital contribution obligation of the shareholders of the company in the case of non-liquidation or the obligation to perform the capital contribution, but according to the above provisions, it can be judged that the enterprise as the executed person at this time has in fact the cause of bankruptcy, that is, "the property is not sufficient to pay off the debts determined by the legal instrument in force".

In the cases of (2021) Guangdong 1971 Zhiyi No. 155 and (2021) Guangdong 1971 Zhiyi No. 266, the creditors' claim to add the original shareholders who have not fulfilled their capital contribution obligations as the executed persons has been supported by the court, and the court held that "the shareholders decide the capital contribution plan according to the actual business needs of the company" does not conform to Article 25 of the the People's Republic of China Company Law, "the articles of association of a limited liability company shall state the following matters:… (V) the provisions on the way, amount and time of capital contribution of shareholders…", the shareholders of the company involved in the case "did not submit other evidence to the court to prove that they had agreed on the time limit of capital contribution in other documents, and failed to prove whether they had actually paid the capital contribution, so they should bear the legal consequences of the failure of proof… The shareholders implied that they had given up the time limit interest of the time limit of capital contribution by their own behavior." However, the author believes that, according to the aforementioned provisions of the Supreme People's Court, even if the shareholders of the two cases submit a certificate that the capital contribution period has been agreed, it should be determined that the capital contribution period has accelerated and expired. This point was issued and implemented on November 8, 2019. It has been further determined in the "Minutes of the National Court Civil and Commercial Trial Work Conference, it stipulates in the" 2. on the accelerated maturity and voting rights of shareholders' capital contributions "under the" (II) on the trial of corporate disputes "that" under the registered capital contribution system, shareholders shall enjoy the benefits of the term in accordance with the law. The people's court shall not support the creditor's request that the shareholders of the outstanding capital contribution period bear supplementary liability for the debts that the company cannot pay off within the scope of the unfunded capital contribution on the grounds that the company cannot pay off the debts due. However, the following circumstances are excluded:(1) in the case of the company as the executed person, the people's court exhausts the enforcement measures and has no property to enforce, and has the reasons for bankruptcy, but does not apply for bankruptcy;(2) after the company's debts are incurred, the company's shareholders (The General Assembly) will decide or otherwise extend the period of shareholder capital contribution."

(II) in liquidation proceedings, the accelerated maturity of shareholders' contributions is expressly provided by law.

Article 22, paragraph 1, of the (II) of the Supreme People's Court on Several Issues Concerning the Application of the the People's Republic of China Company Law stipulates that "at the time of dissolution of a company, the capital contributions not yet paid by shareholders shall be regarded as liquidation property. The capital contributions not yet paid by shareholders include the capital contributions due and payable, as well as the capital contributions not yet due and payable in installments in accordance with the provisions of Articles 26 and 80 of the Company Law." Article 13, paragraph 1, of the (III) of the Supreme People's Court on Certain Issues Concerning the Application of the the People's Republic of China Company Law stipulates that "if a shareholder fails to perform or fails to fully perform his or her capital contribution obligations, and the company or other shareholders request him or her to fully perform his or her capital contribution obligations to the company in accordance with the law, the people's court shall support it." Article 35 of the the People's Republic of China Enterprise Bankruptcy Law stipulates that "if, after the people's court accepts the bankruptcy application, the debtor's contributor has not fully fulfilled its capital contribution obligations, the administrator shall require the contributor to pay the capital contribution paid, without being limited by the time limit of the capital contribution." According to the above provisions, in the stage of self-liquidation or compulsory liquidation, the outstanding capital contributions of shareholders shall be treated as liquidation property, and the liquidation group of the company shall have the right to require the shareholders who have not made capital contributions to fulfill their capital contribution obligations.

When the company entered the liquidation process, a large number of judicial precedents had supported the claim of the liquidation group or the administrator to the shareholders to fulfill their capital contribution obligations in accordance with Article 22 of the (II) of the Provisions of the Supreme People's Court on Several Issues Concerning the Application of the the People's Republic of China Company Law and Article 35 of the the People's Republic of China Enterprise Bankruptcy Law, for example, the part of the civil judgment (2020) Zhejiang 10 min zong No. 2909 "in the opinion of the court" contained in the 8th series of "people's court case selection" (total No. 162) in 2021 stated that "after hanyong company enters liquidation, the period of shareholders' capital contribution expires at an accelerated rate, and the liquidation team shall immediately pay whether hanyong company has surplus distribution before it can reach a conclusion, but the appellant's capital contribution obligation cannot be exempted, the liquidation group requires the appellant to make up the amount of capital contribution, in accordance with the law. Even if Wei Guanghua's distribution of profits is sufficient to cover the amount of capital contribution, it cannot be exempted from the obligation of capital contribution."

However, in the above-mentioned shareholder capital contribution dispute case, the first-instance judgment did not find out in what form shareholder B fulfilled its capital contribution obligation and whether the relevant performance conforms to the provisions of the Company Law on shareholder capital contribution. In view of the fact that the target company entered the compulsory liquidation stage, Jingxing believed that the capital contribution should be found out by the liquidation group designated by the court according to law. However, the second-instance judgment still failed to find out and determine the facts of shareholder B's capital contribution, after the liquidation group has clearly put forward the opinion that the shareholders have not fulfilled their capital contribution obligations, the court of second instance also proposed that the liquidation group should be able to claim the liability of shareholders for capital contribution under the circumstances of proving that the subject company is insolvent. The courts of the second instance did not analyze or explain the application problems or the reasons for excluding the application of Article 22 of the (II) of the Supreme People's Court on Several Issues concerning the Application of the the People's Republic of China Company Law and Article 13 of the (III) of the Supreme People's Court on Several Issues concerning the Application of the the People's Republic of China Company Law.

In the face of this situation, the liquidation group did not take over the actual disposable assets of the subject company in the compulsory liquidation proceedings, and considering that there is no need to pay litigation fees in advance for the application for retrial, the liquidation group may file a retrial application for the aforementioned shareholder capital contribution dispute case, so as to avoid the subsequent blame for not recovering the outstanding capital contributions of the shareholders. On the other hand, the existing assets of the target company cannot pay off the employees' claims, and the liquidation group has already faced the situation of insolvency. The liquidation group should apply for the compulsory liquidation case of the target company to be converted into the bankruptcy liquidation case according to law. However, even in the case of entering the bankruptcy liquidation procedure, the administrator still has no funds to pay the litigation costs of the case of recovering unpaid capital contributions, and also faces an effective judgment rejecting the company's litigation request for recovering unpaid capital contributions, this makes the re-prosecution constitute a duplication of proceedings and cannot be supported. Shareholder B, as an existing creditor of the company, is also the object of the capital contribution, the willingness to advance the litigation costs of the capital contribution case is basically not, which will lead to the manager's ability to recover the liability of shareholder B's capital contribution in the real situation is seriously limited, disguised to make the shareholders who have not paid the capital contribution from the obligation to bear the capital contribution.

In addition, the shareholders who should bear the responsibility of capital contribution include the current shareholders and former shareholders. The second-instance judgment [(2020) Lu 02 min zong No. 12403] of the top ten commercial cases issued by the second civil court of the supreme people's court in 2020, "the appellant Xu qinqin, Changzhou tongshun machinery manufacturing co., ltd., Zhou jieru and the appellee Qingdao zhuxin machinery co., ltd." states that "according to the provisions of article 65 of the contract law, the parties agree that a third person shall perform the debt to the debt to the creditor, if the third party fails to perform the debt or the performance of the debt does not conform to the agreement, the debtor shall bear the liability for default to the creditor. Under the framework of the Company Law, shareholders do not need the consent of the target company to transfer their equity. For the contractual obligation of the company's capital contribution, after the transfer to the post-shareholders (transferees) of the equity, the behavior of canceling the company without making the capital contribution on schedule makes the post-shareholders have the contractual obligation of paying the capital contribution to the company due to the expiration of the capital contribution period. In the case of non-performance, in line with the above-mentioned legal provisions, the third party fails to perform the debt, so the company has to claim the liability for breach of contract to the former shareholders (creditors)"; "Shareholders bear limited liability to the company on the basis of capital contribution, but when the company is dissolved, when the shareholders still fail to make capital contribution on time and the assets are not enough to pay off the debts, the shareholders cannot enjoy the protection of limited liability according to the Company Law, creditors have the right to require shareholders to fulfill their capital contribution obligations and repay external debts within the scope of their capital contributions. The creditor's claim to the shareholder is based on the principle of limited liability established by the company, with the purpose of safeguarding the integrity of the company's capital and safeguarding the due interests of creditors. In this case, the company has been dissolved and canceled, because the former shareholders still have the obligation to make capital contributions to the company under Article 65 of the Contract Law, and in the event of the dissolution and cancellation of the company, the creditors also have the right to require the former shareholders to be jointly and severally liable for the company's debts within the scope of their capital contributions."

In the stage of self-liquidation and compulsory liquidation of the (III), if the amount of the company's debt is much lower than the amount of the shareholders' capital contribution, the shareholders may not be required to pay the full amount of the capital contribution if the shareholders and all creditors reach a debt settlement plan.

Article 17 of the (II) of the Provisions of the Supreme People's Court on Several Issues Concerning the Application of the the People's Republic of China Company Law stipulates that "if the liquidation team appointed by the people's court finds that the company's property is insufficient to pay off its debts when liquidating the company's property and preparing the balance sheet and property list, it may negotiate with the creditors to make the relevant debt settlement plan. If the debt settlement plan is confirmed by all creditors and does not harm the interests of other interested parties, the people's court may approve it in accordance with the application of the liquidation group. After paying off the debts in accordance with the liquidation plan, the liquidation group shall apply to the people's court for a ruling to terminate the liquidation procedure. If the creditor does not confirm the debt settlement plan or the people's court does not approve it, the liquidation group shall apply to the people's court for bankruptcy in accordance with the law." Accordingly, the liquidation group may negotiate with the creditors to produce a debt settlement plan, and if the settlement plan can eventually pay off the debt, the liquidation proceedings shall be terminated in accordance with the law. Based on the self-liquidation and compulsory liquidation stage, the shareholders' capital contribution is the liquidation property of the company, if the shareholders only pay part of the capital contribution payable to pay off all the debts of the company and the liquidation expenses, the remaining unpaid capital contribution may not be paid again, after the company completes the liquidation procedure and cancels, the shareholders' liability for the remaining capital contribution can be relieved.

(IV) in the practice of the Shenzhen "transfer" case, after the creditors' meeting vote, the manager can be known to the amount of claims to the shareholders of the unpaid capital contribution to recover.

Articles 21 and 22 of the guidelines of Shenzhen intermediate people's court on the implementation of the work of administrators in transferred bankruptcy cases stipulate that if the administrator finds that the investor has not fulfilled or has not fully fulfilled the obligation of capital contribution after investigation, the administrator shall recover the capital contribution according to law without being limited by the time limit of capital contribution. If the administrator thinks that the full amount should be recovered and is willing to advance the litigation costs, he may directly file a lawsuit, but if the litigation cost of capital recovery is too high, the amount of the claim may be recovered to the extent that the amount of the claim is known after the vote of the creditors' meeting. The aforementioned provisions, under the condition that the legitimate rights and interests of all creditors are not impaired, allow the administrator to partially recover the outstanding capital contributions of shareholders, solve the dilemma that the existing assets of the bankrupt enterprise are not sufficient to cover the litigation costs, and at the same time reduce the liability of shareholders for part of the capital contributions that exceed the total amount of the company's claims. Although this provision applies to "transfer" cases, "transfer" cases are also insolvency cases, except that the commencement of the insolvency case is converted from the enforcement proceedings, and therefore the application to the insolvency proceedings should not be hindered.

In my opinion, this provision is consistent with the theoretical basis and legal basis that shareholders and all creditors do not need to pay the remaining capital contribution after reaching a debt settlement plan in the aforementioned self-liquidation and compulsory liquidation stages. Article 186, paragraph 2, of the "the People's Republic of China Company Law" stipulates that "the company's property shall be paid separately for liquidation expenses, employees' wages, social insurance expenses and statutory compensation, the taxes owed, and the remaining property after paying off the company's debts. Limited liability companies are distributed in proportion to the capital contribution of shareholders, and joint stock limited companies are distributed in proportion to the shares held by shareholders." If the subscribed capital contribution of the shareholders of the company has fully paid off all the liabilities and liquidation expenses of the company, and there is still a surplus, the remaining part will be distributed to the shareholders according to the proportion of the shareholders' shareholding. In this case, the flow of funds is paid from the shareholders to the company, and then the company will pay the remaining part back to the shareholders. Based on the "simulation" of this hypothetical situation, pushing forward from the result, in the case that shareholders do not need to recover the remaining distribution, in fact, shareholders do not need to pay too much capital contribution, and in the process, creditors are paid off, even if there is a deviation between the company's paid-in capital and the registered capital, it is also within the framework of the registered capital subscription system set by law.

In the (V) bankruptcy liquidation proceedings, the capital contribution owed by the shareholders to the company cannot be set off against the debts owed by the company to the shareholders.

In judicial practice, it often happens that the controlling shareholder of the company provides a large amount of funds to the company, and the relevant funds are reflected as "current funds" in the bank flow and financial information. However, there is no information in the company's industrial and commercial registration data to show that the controlling shareholder has paid the capital in full. The financial information shows that the paid-in capital of the company is zero, and the company enters the liquidation stage, the controlling shareholder, on the other hand, claims to the liquidation group or administrator that the amount it pays to the company is a capital contribution, or that the amount owed by the company is set off against the amount of its due capital contribution, but such claim by the shareholder may not be supported by law. For example, the Beijing No.2 Intermediate People's Court stated in the "opinion of the court" part of the civil judgment (2023) Beijing 02 Minzong No. 7631 that "Li Moumou's appeal claimed that Chen Chengquan, the former sole shareholder of Minghe Company, had completed the obligation to pay capital contribution. The Shanghai Pudong Development Bank business certificate/receipt submitted in the second instance showed that Chen Chengquan or Li X had made many payments to Minghe Company, however, the time span is long and the amount is different, which cannot be clearly reflected as capital contribution, and there is no relevant certification material for Chen Chengquan or Li Moumou to complete the paid-in capital contribution obligation in the industrial and commercial registration data of Minghe Company, which is not sufficient to prove that Chen Chengquan or Li Moumou has completed the paid-in capital contribution obligation. Under the condition that Li Moumou does not provide other sufficient evidence to prove his claim, the court's appeal."

Under the implementation of the company's registered capital subscription system, the paid-in capital contribution of shareholders is no longer a condition for the establishment of the company and the acquisition of a business license, and the paid-in capital contribution of shareholders does not require industrial and commercial registration. In this case, in the event of a dispute, Whether the shareholders have fulfilled their capital contribution obligations depends on whether the relevant evidence provided by the shareholders is sufficient.

Article 28, paragraph 1, of the Company Law of the the People's Republic of China stipulates that "shareholders shall pay in full and on time the amount of their respective capital contributions as stipulated in the articles of association of the company. Where shareholders make capital contributions in currency, they shall deposit the full amount of the capital contribution in currency into the bank account opened by the limited liability company; where they make capital contributions in non-monetary property, they shall go through the formalities for the transfer of their property rights in accordance with the law." Article 30 stipulates that "after the establishment of a limited liability company, a certificate of capital contribution shall be issued to the shareholders. The certificate of capital contribution shall contain the following items: (1) the name of the company; the date of establishment of the (II) company; the registered capital of the (III) company; the names of the (IV) shareholders, the amount of capital contribution paid and the date of capital contribution; the serial number of the (V) capital contribution certificate and the date of issuance. The certificate of capital contribution shall be sealed by the company." Therefore, the shareholder's evidence that it has fulfilled its obligation to pay-in capital includes, at a minimum, a certificate of payment of its capital contribution to the company's account or a certificate of transfer registration for the completion of the transfer of property rights and a certificate of capital contribution issued by the company. In addition, the relevant resolutions of the board of directors and the shareholders' meeting on the confirmation of shareholders' capital contribution and the resolutions of the board of directors, the capital verification report, asset evaluation report, equity transfer agreement, annual inspection report, etc. of the paid-in capital can be reflected in the industrial and commercial files, and the proof of the entry of paid-in capital can be shown in the financial data, which can be used as proof of the capital contribution paid by shareholders.

In the event that a shareholder's payment to the company cannot be recognized as a shareholder's paid-in capital contribution, the shareholder cannot offset the amount owed by the company against the amount of its due capital contribution. Article 46 of the (II) Provisions of the Supreme People's Court on Several Issues Concerning the Application of the the People's Republic of China Enterprise Bankruptcy Law stipulates that "if the debtor's shareholders claim to offset the following debts with the debts owed by the debtor, and the debtor's manager raises an objection, the people's court shall support it: (1) the debtor's shareholders owe the debts to the debtor due to non-payment of the debtor's capital contribution or evasion of capital contribution, if a shareholder has a claim on the bankrupt enterprise, he shall declare the claim to the administrator of the bankrupt enterprise in accordance with the law, but the capital contribution owed by the shareholder to the bankrupt enterprise shall be made up in accordance with the law, or the administrator shall recover it in accordance with the law, and the two cannot be set off against each other. Combined with the provisions of No. 32 of the the People's Republic of China Enterprise Bankruptcy Law, it can also be interpreted as that the bankrupt enterprise cannot pay off the debts owed to the shareholder by the creditor's rights of the outstanding capital contribution to the shareholder, otherwise it will constitute the individual repayment of the bankrupt enterprise to the shareholder. Under the situation that other ordinary creditors need to be paid according to the unified and relatively low bankruptcy settlement rate according to law, the shareholder has received 100 percent of compensation, this makes the rate of repayment inconsistent and unfair among creditors, and therefore such set-off should be prohibited. In the civil judgment No. 736 (2019) Zhejiang People's Court of Higher People's Court of Zhejiang Province, it is stated that "registered capital is the material basis for the operation of the company, and the withdrawal of registered capital by shareholders constitutes infringement on the company", "Although Huang Xiaodong has repaid more than 6.78 million yuan of loan for EBA Company and claimed the right of set-off, under the circumstance that EBA Company has entered the bankruptcy procedure, it is different from the right of set-off in the civil law, the right of bankruptcy offset highlights the guarantee function of its debt, that is, the company's registered capital is the company's debt repayment guarantee for all creditors, rather than just the capital contribution obligation that shareholders should perform to the company. Since the interest subject of returning the debt of evaded capital contribution involves shareholders, the company and the creditor's rights, under the condition that there is no correspondence between the subjects, Huang Xiaodong has more than 6.78 million bankruptcy claims to EBA, it cannot be offset against the debt of the evaded capital contribution that should be returned to the company", that is, the specific application of the aforementioned provisions.

As for whether the capital contribution owed by shareholders in the self-liquidation and compulsory liquidation procedures can offset the debts owed by the company to shareholders, there is no explicit stipulation at present. However, according to the principle of "freedom without prohibition by law", there is no situation that the company's assets are not enough to pay off the debts in the self-liquidation and compulsory liquidation procedures. In the case that the company's assets (including shareholders' capital contribution) are enough to pay off all the debts and there may be surplus, this kind of set-off does not harm the interests of other creditors, so the author thinks that this kind of situation can be set off.

Based on the above analysis, it can be seen that although the company's registered capital subscription system relaxes the time limit for shareholders' paid-in capital, based on the authenticity and legality of shareholders who should be responsible for their paid-in capital, in the company's liquidation procedure, based on the protection of creditors' interests, the reduction and exemption of shareholders' capital contribution obligations should be accelerated and paid-in full, except in accordance with the legal circumstances.

(This article only represents the author's own views)

 

Lawyer Jiang Shan

 

[Practice Profile] Partner of Shengdian Law Firm, currently a director of the Bankruptcy Law Research Association of Shenzhen Law Society, a supervisor of Shenzhen Bankruptcy Administrators Association, a member of the Enterprise Bankruptcy Liquidation Professional Committee of Shenzhen Lawyers Association, and the bankruptcy administrator (Level 2) The co-leader of the team and the editor in charge of "Shengdian Lawyer Review" have won the second prize of "2019-2022 Guangdong-Hong Kong-Macao Greater Bay Area Legal Service Outstanding Cases" issued by Guangdong Lawyers Association, he has won the "Outstanding Young Lawyer Award", "Professional Team Award" and "Professional Contribution Award" of Shengdian Law Firm for many times ".

 

[Practice Area] Legal business in corporate, real estate, finance, and labor relations, he has provided customers with legal advice, due diligence, negotiation, issuance of professional legal opinions, drafting of legal documents, review of contracts, participation in litigation and mediation on matters such as enterprise establishment, liquidation and cancellation, equity transfer, merger and acquisition, asset reorganization, land use right transfer, transfer and mortgage, housing lease, construction supervision, bank non-performing assets disposal, labor disputes, etc.

 

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