ABSTRACT
This chapter attempts to answer the question of what property is from the perspective of history and comparison. The Roman jurist Gaius divides property (res) into intangible property (res incorporales) and tangible property (res corporales). Res in ancient Roman law is an extremely broad concept. French Civil Code takes bien as its conceptual basis, resulting from history rather than logical thinking. German Civil Code creates a narrower concept of Sachen: it is limited to being corporeal. This concept serves as a basis for the distinction between Sachenrecht and Verbintenissenrecht. Property in common law is very broad, like res in ancient Roman law. In contemporary society, virtual property, such as Bitcoin, gaming equipment, and emission rights, emerges rapidly. For these types of virtual property, the Chinese Civil Code provides a reference (art. 127) to other special laws for virtual property.
