China’s internet sector is a curious paradox – it enjoys the most foreign equity investment of any part of the Chinese economy, while at the same time, foreigners do not own a single share.

A curious regulatory loophole known as a VIE, or variable interest entity, has allowed foreigners to get around Beijing’s prohibitions against foreign ownership of internet assets. They have amassed huge holdings in companies such as Tencent, Baidu and Alibaba, the ecommerce group that on Tuesday filed for a US IPO that could value it at up to $200bn.

Prospective investors in Alibaba’s listing – likely to raise about $20bn and to be the biggest stock flotation in the world since Facebook – will know that in any dispute with Alibaba’s Chinese investors, their shares could be invalidated and rendered worthless in a Chinese court.