Understanding the market

Key commercial differences between US and UK M&A norms

There are a number of differing market norms on both sides of the Atlantic. It's important to understand these differences in approach to help bridge the expectation gap on transatlantic deals and facilitate a conciliatory and faster transaction process. Below we set out some the key differences between market practice in the UK/Europe and the US.

Governing law


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Pricing mechanisms


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Conditions


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Liability and recourse


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Restrictive covenants


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PE-related differences


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Governing law


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Pricing mechanisms


Read more

Conditions


Read more

Liability and recourse


Read more

Restrictive covenants


Read more

PE-related differences


Read more
We know what US buyers want and how to deliver it. Our long history of advising US companies on their overseas acquisitions and team on the ground in San Francisco to complement our UK and European strength mean we can navigate and bridge legal, market and cultural differences to deliver a successful result.

Deal structure

Overarching structure


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Treatment of employees


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Earn-outs


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Share consideration


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Acquihires


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Overarching structure


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Treatment of employees


Read more

Earn-outs


Read more

Share consideration


Read more

Acquihires


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