Prudent investors may gain an advantage by leveraging their knowledge of differences in private M&A market practices between Canadian and U.K.-style purchase agreements. While Canadian M&A takes many cues from the United States and Europe, it is not a carbon copy of either. Canadian private M&A purchase agreements are generally more buyer-friendly whereas U.K. agreements tend to be more seller-friendly. Businesses involved in cross-border transactions between the two jurisdictions should consider the following key differences.
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