Comparing Takeover Laws in the UK, India and Singapore

Abstract

This paper makes a first of its kind comparative analysis of the Takeover Regulations in the UK, India and Singapore. It examines how the economic, social and political context of these countries shapes its takeover regulations. Special attention is given to the impact of shareholding patterns and policy objectives on the Regulations. The authors take four major areas of comparative analysis:

- thresholds for mandatory offers; - penalties for breach/non-compliance of the regulations; - self-regulation and the need for providing a statutory basis for the regulations; and finally, - the role of the courts under each system.

Keywords: Corporate Law, Securities Law, Comparative Law, Takeovers, Singapore, UK, India

JEL Classification: K22