Reference Case: Zhao Liangchen v. Shen Min and Hainan Shengde Huankai Real Estate Co., Ltd.

Where a shareholder rapidly transfers paid-in capital back to a personal account after incorporation and cannot prove that the funds were lawfully used for the company's business, the conduct constitutes withdrawal of capital. A later shareholder resolution internally setting off loans against the contribution has only internal effect, cannot defeat outside creditors, and does not prove that the contribution was replenished.