建筑物区分所有权作为一项重要的法律制度,已为英美法系和大陆法系所普遍确立。然而,在我国迄今为止尚未制定建筑物区分所有权法,具有明显的滞后性。本文运用分析比较法,主要借鉴法国、瑞士、日本及我国台湾地区有关建筑物区分所有权的立法规定,结合我国建筑物区分所有权的特点,对建筑物区分所有权的基地使用权和部分产权两个方面作以分析探讨,提出一些具体立法建议,以便有益于建立和完善我国建筑物区分所有权制度。 Distinguishing ownership of buildings as an important legal system has been universally established for common law and civil law jurisdictions. However, so far in our country has not yet made the building ownership separation law, with obvious lag. In this paper, we use the comparative analysis method, mainly from the legislative provisions of France, Switzerland, Japan and Taiwan in China on building ownership differentiation, combined with the characteristics of building ownership differentiation in our country, two aspects of the land use right and partial property rights For analysis and discussion, put forward some specific legislative proposals, in order to benefit the establishment and improvement of China’s building ownership separation system.