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Industries · Private Capital & Family Business

Private Equity across borders

What a business in private equity usually needs to sort out when it works in more than one country, and who at WONE Global handles it.

Typical issues

What Private Equity businesses check first

  1. 01Fund and acquisition-vehicle structure
  2. 02Management incentive plans across countries
  3. 03Foreign-investment approvals and exit planning

General orientation, not advice. How each applies depends on your markets — your WONE Global professional confirms it.

Services

The services involved

Industry experience

WONE Global Partners with Private Capital & Family Business experience

If no professional is listed for your market, WONE Global arranges qualified local expertise and names them before work begins.

What the guides say · Investment & Transactions

Deals and investment, market by market

Deals and investment is usually the first thing private equity businesses check. Choose a market to see its rules.

Africa4 markets
South AfricaEssentials · source-checkedMergers above the intermediate threshold must be notified to the Competition Commission, and the thresholds rose on 1 May 2026. Takeover rules apply to public and certain private companies.
EgyptEssentials · source-checkedOnly the tax treatment of share disposals could be confirmed. Merger control, takeover rules and insolvency need to be checked from official sources.
KenyaEssentials · source-checkedAcquisitions of control of listed companies follow the Capital Markets (Take-Overs and Mergers) Regulations, and insolvency is governed by the Insolvency Act 2015.
NigeriaEssentials · source-checkedNotifiable mergers must be approved by the FCCPC before implementation, and offshore deals can be caught where the parties sell into Nigeria. Corporate capital gains are taxed at 30 percent.
Australia1 market
AustraliaEssentials · source-checkedForeign acquirers may also need FIRB approval, and takeovers of listed and larger companies follow federal takeover rules. Insolvency is federal and offers administration, liquidation and a small business restructuring process.
Central & Eastern Europe1 market
PolandEssentials · source-checkedDeals meeting UOKiK turnover thresholds need clearance before closing, with fines for gun-jumping. Poland may also screen foreign investment under the EU framework, but the national rules were not confirmed here.
East Asia4 markets
ChinaEssentials · source-checkedMergers meeting turnover thresholds must be notified to SAMR before closing under the Anti-Monopoly Law, amended in 2022. Thresholds were raised in January 2024.
JapanEssentials · source-checkedShare acquisitions meeting domestic turnover tests of JPY 20 billion for the acquirer group and JPY 5 billion for the target must be notified to the Japan Fair Trade Commission, with a 30-day waiting period.
South KoreaEssentials · source-checkedThe Korea Fair Trade Commission reviews mergers where one party has KRW 300 billion and the other KRW 30 billion of assets or sales, with share thresholds of 20 or 15 percent. Review takes 30 days, extendable by up to 90.
Hong KongEssentials · source-checkedHong Kong's Competition Ordinance is enforced by the Competition Commission through the Competition Tribunal, with the Communications Authority sharing jurisdiction in telecoms and broadcasting.
GCC5 markets
United Arab EmiratesFull guideDeals that cross the federal merger control thresholds (UAE turnover above AED 300 million in the relevant market, or a combined share above 40%) must be notified to the Ministry of Economy and Tourism at least 90 days before completion…
Saudi ArabiaFull guideAcquisitions in Saudi Arabia can need merger clearance from the General Authority for Competition (GAC), registration or approval from the Ministry of Investment (MISA) and, for listed targets, compliance with the Capital Market…
QatarEssentials · source-checkedCompetition law requires notification of certain acquisitions and mergers to the competition authority at the Ministry of Commerce and Industry. Listed company transactions are regulated by the Qatar Financial Markets Authority.
BahrainEssentials · source-checkedTakeovers of listed companies are regulated by the Central Bank of Bahrain. A 2018 bankruptcy law introduced a reorganisation procedure modelled on debtor-in-possession restructuring.
OmanEssentials · partly source-checkedOman's competition law requires approval of economic concentrations that may lead to dominance. Listed company transactions are regulated by the Financial Services Authority, with shares traded on the Muscat Stock Exchange.
Latin America3 markets
BrazilEssentials · source-checkedDeals above turnover thresholds must be cleared by CADE before closing. Early completion is penalised with fines and nullity. CADE's review period is capped at 240 days, extendable by 90.
ChileEssentials · source-checkedListed company deals fall under the securities law and the CMF. Insolvency is handled under a 2014 law providing for reorganisation and liquidation procedures.
ColombiaEssentials · source-checkedInsolvency is governed by Law 1116 of 2006 and handled mainly by the Superintendencia de Sociedades. Listed company deals fall under Superintendencia Financiera rules.
Nordics2 markets
SwedenEssentials · partly source-checkedDistressed businesses can use bankruptcy or company reconstruction proceedings.
NorwayEssentials · partly source-checkedConcentrations with combined Norwegian turnover above NOK 1 billion must be notified to the Norwegian Competition Authority unless only one party has Norwegian turnover above NOK 100 million.
North America3 markets
United StatesFull guideDeals in the United States are shaped by three federal filters: Hart-Scott-Rodino merger notification to the FTC and DOJ, national security review by CFIUS for foreign buyers, and, for US investors going outward, Treasury's outbound…
CanadaEssentials · source-checkedLarge mergers must be notified to the Competition Bureau and cannot close during a 30-day waiting period, while acquisitions of control by non-Canadians fall under the Investment Canada Act.
MexicoEssentials · source-checkedMerger control and antitrust enforcement now sit with the Comisión Nacional Antimonopolio under the reformed Federal Economic Competition Law.
South Asia1 market
IndiaFull guideAcquisitions, mergers and amalgamations that cross the asset or turnover thresholds in the Competition Act 2002, or that are worth more than Rs 2,000 crore where the target has substantial business operations in India, must be approved by…
Southeast Asia5 markets
SingaporeFull guideSingapore has no general foreign-investment approval for acquisitions, but stakes in entities designated under the Significant Investments Review Act 2024 need notification or prior approval, and regulated sectors have their own…
MalaysiaEssentials · source-checkedThe 2024 amendments to the Companies Act 2016 strengthened Malaysia's corporate rescue tools, including wider access to voluntary arrangements, moratoria for schemes and super-priority rescue financing.
VietnamEssentials · source-checkedForeign acquisitions must meet market access conditions and, in defined cases, be registered before the change of shareholders, including where foreign ownership would exceed 50%. Merger control and insolvency rules still need confirmation.
IndonesiaEssentials · partly source-checkedAcquisitions of listed companies follow OJK takeover rules, and insolvency is handled by the Commercial Courts through bankruptcy or suspension of payment proceedings.
ThailandEssentials · source-checkedMergers are controlled under the Trade Competition Act B.E. Takeovers of listed companies follow SEC tender offer rules, and insolvency is handled under the Bankruptcy Act, including business reorganisation.
UK & Ireland2 markets
United KingdomFull guideUK deals face two separate government reviews. National security screening under the National Security and Investment Act 2021 is mandatory and suspensory for share acquisitions in 17 sensitive sectors, with no turnover threshold and void…
IrelandEssentials · source-checkedMergers above turnover thresholds must be notified to the CCPC before completion. The thresholds changed twice in 2026: higher thresholds lapsed on 30 September 2026 and the old EUR 60 million and EUR 10 million tests apply until the…
Western Europe7 markets
GermanyFull guideDeals in Germany can need clearance from the Bundeskartellamt under turnover thresholds or a separate EUR 400 million transaction-value threshold, and from the economics ministry where a non-EU buyer acquires a stake in a sensitive…
FranceFull guideFrench merger thresholds rose on 1 September 2026 to EUR 250 million combined worldwide turnover and EUR 80 million French turnover for two parties, and notifiable deals cannot close before clearance.
NetherlandsEssentials · source-checkedMergers above turnover thresholds need ACM approval before completion, but the thresholds themselves could not be confirmed. Investment screening and insolvency rules were not confirmed.
SwitzerlandEssentials · source-checkedMergers above turnover thresholds must be notified to COMCO and may not close during the review period. Investment screening and insolvency rules could not be confirmed on an official page.
ItalyEssentials · source-checkedMergers above the AGCM turnover thresholds need prior notification, and the AGCM can call in some smaller deals.
SpainEssentials · source-checkedSpanish merger control, foreign investment screening and insolvency rules could not yet be confirmed from official sources run. Only the pending EU-level revision of FDI screening was confirmed.
LuxembourgEssentials · source-checkedSince 1 September 2023, non-EU/EEA investors taking control of entities in critical sectors must notify the Minister of the Economy before completion. Merger control and insolvency rules were not confirmed.
Wider Middle East2 markets
TürkiyeEssentials · source-checkedMerger notification thresholds were raised on 11 February 2026 to TRY 3 billion aggregate and TRY 1 billion individual Turkish turnover, with a narrower technology exception.
IsraelEssentials · source-checkedMergers meeting turnover or market share thresholds must be notified to the Israel Competition Authority and approved before completion.
Other markets20 markets
ArgentinaEssentials · source-checkedThe Competition Law (Ley 27.442) requires notification of concentrations where combined Argentine turnover exceeds 100 million unidades móviles, and provides for a prior-control model once the national competition authority has been…
AustriaEssentials · source-checkedForeign investments in sensitive sectors by non-EU investors are screened under the Investment Control Act. Insolvency and restructuring follow the Insolvency Code and the Restructuring Code.
BangladeshEssentials · partly source-checkedThe Competition Act 2012 established the Bangladesh Competition Commission and allows it to review combinations that may harm competition. Listed company takeovers follow BSEC rules.
BelgiumEssentials · partly source-checkedSince 1 July 2023 investments by non-EU investors in sensitive sectors have been screened by the Interfederal Screening Commission. Insolvency and judicial reorganisation are governed by Book XX of the Code of Economic Law.
CameroonEssentials · partly source-checkedMerger control can arise at both CEMAC regional level and national level. Insolvency follows the OHADA Uniform Act, which offers preventive and collective procedures.
CyprusEssentials · source-checkedConcentrations of major importance must be notified to the Commission for the Protection of Competition. Takeovers of listed companies are governed by Law 41(I)/2009 and supervised by CySEC.
Czech RepublicEssentials · source-checkedDeals meeting the CZK 1.5 billion and CZK 250 million turnover tests need ÚOHS clearance before closing, with fines for gun-jumping. An amendment to raise the thresholds was being prepared in September 2026 but was not in force.
DenmarkEssentials · source-checkedListed company takeovers follow capital markets rules. Insolvency is handled by the probate courts, with a reconstruction procedure available for viable businesses.
EcuadorEssentials · partly source-checkedSecurities and listed companies are supervised by the SCVS. Insolvency and restructuring rules have been reformed in recent years and should be checked for each case.
FinlandEssentials · source-checkedListed company takeovers follow the Securities Markets Act and the Helsinki Takeover Code. Insolvent businesses may go into bankruptcy or use a court-led restructuring procedure.
GreeceEssentials · source-checkedTakeovers of listed companies are supervised by the Hellenic Capital Market Commission. A single insolvency code adopted in 2020 covers out-of-court workouts, restructuring and bankruptcy.
HungaryEssentials · source-checkedHungary has two foreign investment screening regimes, one of which can apply to EU investors as well as non-EU investors.
MoroccoEssentials · source-checkedTakeovers of listed companies fall under the AMMC, and insolvency proceedings follow Book V of the Commercial Code, reformed in 2018.
New ZealandEssentials · source-checkedMerger control under the Commerce Act 1986 is voluntary, but the Commerce Commission can take enforcement action against a deal likely to substantially lessen competition, so clearance is common for larger deals.
PanamaEssentials · source-checkedCompetition law is enforced by the Autoridad de Protección al Consumidor y Defensa de la Competencia (ACODECO), and merger notification is voluntary.
PhilippinesEssentials · source-checkedInsolvency and rehabilitation are governed by the Financial Rehabilitation and Insolvency Act.
PortugalEssentials · source-checkedMergers meeting market-share or turnover tests must be notified to the Competition Authority. Acquisitions of strategic assets by non-EU/EEA investors can be reviewed under Decree-Law 138/2014. These points come from a 2025 law firm guide.
RwandaEssentials · source-checkedMergers and acquisitions are reviewed by the Rwanda Inspectorate, Competition and Consumer Protection Authority, and regional deals may also fall under COMESA.
UgandaEssentials · source-checkedTakeovers of listed companies are regulated by the Capital Markets Authority, and insolvency is governed by the Insolvency Act 2011.
ZambiaEssentials · partly source-checkedTakeovers of listed companies fall under the Securities and Exchange Commission, and insolvency is governed by the Corporate Insolvency Act 2017.

Our full guides are checked against official sources. Guides drafted with AI are marked as such. None of this is legal or tax advice.

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