Comparative Legal Analysis of Cross-border Mergers and Acquisitions in the EU and the EAEU

Abstract

This thesis provides a comprehensive comparative legal analysis of cross-border mergers and acquisitions within two different regional integration structures. The purpose of this work is to identify differences and similarities in the approach to cross-border corporate consolidation of the two integrations, studying their institutional, legal and procedural aspects. This work confirms that the degree of legal harmonization within the integration block has serious implications for the effectiveness of cross-border mergers and acquisitions. The study identifies the core obstacles within the EAEU, such as overlapping regulatory jurisdictions, the absence of unified merger procedures, inconsistent approaches to shareholder protection, and restrictions on capital movement. These barriers collectively limit the role that mergers and acquisitions could otherwise play as a engine of deeper economic integration. Based on the long-term developed legislative framework of the EU, the thesis proposes a step-by-step roadmap for harmonization, adapted to the current institutional realities of the EAEU.