Abstract
Mergers and Acquisitions (M&A) are critical strategic tools in corporate growth, market consolidation, and value creation. This paper analyzes the legal and regulatory frameworks governing M&A transactions in Sri Lanka, the United Kingdom (UK), and Singapore. Emphasis is placed on recent legislative developments, the roles of key regulatory bodies, and the practical steps involved in executing M&A deals. The comparative approach highlights strengths and challenges across jurisdictions, offering valuable insights for legal practitioners, investors, and policymakers.
1. Introduction
Mergers and Acquisitions represent a pivotal mechanism through which businesses restructure, expand, and enter new markets. The execution of M&A transactions is complex and heavily influenced by the legal and regulatory environment of the jurisdiction involved.
In an increasingly globalized economy, understanding the evolution of M&A regulation and its practical application is vital. This paper focuses on Sri Lanka, the UK, and Singapore, jurisdictions with differing legal traditions but each offering instructive models of M&A regulation.
2. Strategic Objectives and Practical Execution of M&A
Mergers and Acquisitions (M&A) serve as powerful tools for corporate strategy and structural transformation. The primary motivations behind M&A transactions include horizontal integration (expanding market share by acquiring competitors), vertical synergy (acquiring entities along the supply chain to increase efficiency), diversification (entering new industries or markets to mitigate risks), market entry (penetrating new geographical or product markets), and financial engineering (achieving tax or capital structure efficiencies). These strategic objectives are context-dependent and typically form the foundation for the rationale behind any M&A transaction.
The first step in executing an M&A transaction is strategic planning, which involves identifying and evaluating potential targets in line with the acquiring company’s long-term business strategy. This phase includes assessing the target’s market position, brand equity, product portfolio, and growth potential. The acquiring firm must ensure that the transaction aligns with its financial goals, competitive positioning, and industry outlook. Board-level discussions, strategic fit assessments, and initial outreach or expressions of interest typically occur during this phase.
The second phase is due diligence, which is critical to identifying and quantifying potential risks and liabilities. This involves a thorough review of the target company’s legal standing, financial health, tax compliance, intellectual property rights, employment contracts, litigation risks, environmental issues, and operational strengths and weaknesses. Legal due diligence ensures there are no hidden contractual obligations or regulatory violations, while financial due diligence validates reported earnings and assets. This stage enables the acquirer to either renegotiate terms or walk away if unacceptable risks are uncovered.
Following due diligence, the acquirer undertakes valuation and financing of the proposed transaction. Valuation methodologies commonly used include the Discounted Cash Flow (DCF) method, analysis of comparable transactions, and earnings multiples such as EV/EBITDA (earnings before interest, taxes, depreciation, and amortization). The choice of method depends on the nature of the business and availability of reliable data. Once a valuation range is established, the acquirer explores financing options—whether through internal reserves, bank loans, issuance of shares or bonds, or a combination of these. The financing structure affects the overall cost and viability of the transaction.
Negotiation and deal structuring is the next key phase, where parties agree on the transaction format—whether it will be a share purchase, asset purchase, or a merger. This stage also involves negotiation of representations and warranties, indemnities, post-closing obligations, earn-outs, and conditions precedent. Tax implications, governance arrangements, and integration mechanisms are also discussed. The structure chosen must be legally sound, tax efficient, and operationally feasible for both parties.
Subsequently, the transaction must comply with all regulatory filings and approvals applicable under the laws of the relevant jurisdiction. This includes obtaining merger clearance from competition authorities (where thresholds are met), making disclosures under takeover codes (if the target is publicly listed), and seeking approvals from sector-specific regulators (such as telecom or banking regulators). In cross-border deals, approvals may be required in more than one jurisdiction. Timely and comprehensive regulatory compliance is vital to avoid delays, penalties, or deal termination.
Finally, integration planning is executed to ensure a smooth transition and realization of synergies post-acquisition. This includes aligning organizational structures, integrating information systems, harmonizing HR policies, consolidating operations, and ensuring cultural compatibility. Communication with internal and external stakeholders is crucial to maintaining trust and business continuity. Successful integration often determines whether the anticipated value of the transaction will materialize, making this a critical post-closing activity.
3. Legal and Regulatory Framework in Sri Lanka
Governing Laws and Regulatory Bodies
The legal regime governing Mergers and Acquisitions in Sri Lanka is primarily rooted in the Companies Act No. 7 of 2007, which provides the statutory framework for mergers, amalgamations, and share acquisitions. Specifically, Sections 239 to 246 of the Act set out the procedural requirements for amalgamations, including board approvals, shareholder resolutions, solvency assessments, and court-sanctioned schemes. The Companies Act also regulates the transfer of shares, the rights of minority shareholders, and corporate governance practices during structural changes.
In addition to the Companies Act, the Securities and Exchange Commission Act No. 19 of 2021 governs the conduct of M&A transactions involving public listed companies. The Act empowers the Securities and Exchange Commission of Sri Lanka (SEC) to oversee takeovers, monitor market abuse, and enforce disclosure and investor protection standards. The Act plays a central role in enhancing transparency, particularly in relation to share transactions, material announcements, and insider trading during takeover processes.
One of the most important regulatory instruments applicable to public listed company M&A activity is the Takeovers and Mergers Code of 1995 (as amended), also known as the TOM Code. Administered by the SEC, this Code sets out the rules for acquiring substantial control of listed entities and ensures that all shareholders are treated equitably. The Code’s primary objective is to protect minority shareholders during acquisitions by imposing fair pricing and disclosure requirements on offerors.
While Sri Lanka does not have a standalone competition law, merger control oversight is exercised through the Consumer Affairs Authority Act under which the Sri Lanka Competition Commission operates. However, the competition law framework is underdeveloped, with no comprehensive merger notification or clearance regime. The lack of a robust competition authority and defined thresholds for pre-merger notification creates uncertainty, particularly in large or cross-sector M&A transactions, and highlights the need for legislative reform in line with international best practices.
The Takeovers and Mergers Code (TOM Code) becomes applicable when an acquirer obtains or intends to acquire 30% or more of the voting rights in a listed company. This threshold triggers a mandatory offer requirement, compelling the acquirer to make an offer to all remaining shareholders. The Code is designed to ensure equitable treatment and transparency, and it imposes a specific timeline within which the offer document must be submitted to the SEC and dispatched to shareholders.
The TOM Code also establishes pricing rules by requiring that the offer price not be lower than the highest price paid by the acquirer or any of its concert parties during the preceding six months. This prevents discriminatory pricing and ensures that minority shareholders receive a fair premium for their shares. Furthermore, the Code mandates comprehensive disclosure in offer documents, including details on the acquirer’s intentions, financing arrangements, and any prior dealings with the target. These obligations are intended to uphold fairness, prevent coercive takeovers, and provide adequate information for shareholders to make informed decisions.
In the context of private company M&A, transactions are governed largely by contractual negotiations and do not fall within the scope of the TOM Code or SEC supervision. As a result, private M&As in Sri Lanka tend to follow commercial practices typical of common law jurisdictions, including share purchase agreements, asset transfers, and shareholder consent mechanisms. These transactions typically require robust legal due diligence and clearly drafted representations and warranties to safeguard the acquirer.
For cross-border M&A transactions, particularly those involving significant foreign direct investment (FDI), prior approval from the Board of Investment (BOI) of Sri Lanka may be necessary. The BOI plays a key role in facilitating inward investment and may impose conditions or incentives depending on the sector, scale of investment, and strategic importance. FDI transactions involving land acquisition, infrastructure, or utilities may also be subject to additional scrutiny under national interest policies.
A major regulatory challenge in Sri Lanka is the fragmented nature of oversight and the absence of a consolidated merger control regime. The coexistence of multiple regulatory bodies—including the SEC, BOI, and Consumer Affairs Authority—often leads to overlapping jurisdictions, inconsistent timelines, and procedural uncertainty. Furthermore, the absence of a modern competition law with enforceable merger thresholds and review timelines poses a risk for both domestic and international investors. Regulatory reform is essential to improve predictability and ensure that Sri Lanka remains an attractive destination for M&A activity.
4. Legal and Regulatory Framework in the United Kingdom
Governing Laws and Regulators
The regulatory framework governing Mergers and Acquisitions in the United Kingdom is comprehensive and well-established, primarily anchored in the Companies Act 2006. This Act governs corporate structure and procedural aspects of M&A transactions, particularly schemes of arrangement, which are frequently used for public company mergers. Schemes of arrangement are court-approved procedures that allow a company to reorganize its share capital, merge with another entity, or undergo restructuring, subject to the approval of a majority in number representing 75% in value of shareholders voting at a scheme meeting. The flexibility and binding nature of schemes make them a preferred mechanism for complex M&A activity in the UK.
Central to the regulation of takeovers in the UK is the UK Takeover Code, formally known as the City Code on Takeovers and Mergers. This Code is administered and enforced by the Takeover Panel, an independent body established to oversee fairness and transparency in takeover bids. The Code applies to all public companies that are registered in the UK and listed on regulated exchanges, including the London Stock Exchange (LSE). It provides a detailed framework of rules governing how takeover bids should be conducted, including how and when an offer must be made, required disclosures, and the conduct of directors during a bid process. Its objective is to ensure that shareholders are treated fairly and that takeover activity takes place within a clear and predictable legal structure.
The Competition and Markets Authority (CMA) plays a critical role in overseeing merger control and enforcing the UK’s competition laws. The CMA is responsible for investigating whether mergers and acquisitions may lead to a substantial lessening of competition in any market within the UK. This includes both domestic and cross-border transactions that meet the relevant jurisdictional thresholds. The CMA can intervene to prohibit a merger, require structural remedies, or impose conditions to safeguard competitive market structures. Its role has become even more significant in the post-Brexit context, as the UK has assumed independent responsibility for competition review of mergers that were previously within the purview of the European Commission.
The regulatory landscape is further supported by the Financial Conduct Authority (FCA) and the London Stock Exchange (LSE), both of which contribute to capital market oversight and ensure compliance with listing rules, disclosure obligations, and market conduct standards. The FCA regulates investment firms and securities markets under the Financial Services and Markets Act 2000 and ensures that information asymmetry, insider trading, and market manipulation are adequately addressed. The LSE imposes continuing obligations on listed companies, particularly in the context of material transactions, shareholder communications, and the issuance of circulars during an M&A process.
The UK Takeover Code
The UK Takeover Code is a cornerstone of M&A regulation in the United Kingdom, designed to protect the interests of shareholders and ensure that all takeover activity adheres to principles of fairness, transparency, and equal treatment. The Code applies to all public companies listed in the UK, regardless of whether the bidder is foreign or domestic. Its jurisdiction is triggered when an acquisition results in a person (or group acting in concert) holding 30% or more of the voting rights in a target company. Once this threshold is crossed, the Code mandates a mandatory offer to all remaining shareholders at the highest price paid by the acquirer during the prior 12 months, thereby preventing partial or coercive acquisitions.
Another hallmark of the Code is the “put up or shut up” rule, which requires a potential bidder to announce a firm intention to make an offer or publicly withdraw within 28 days of being publicly named in connection with a possible bid. This provision is designed to prevent market speculation and protect target companies from prolonged uncertainty. The Takeover Panel plays an active supervisory role during this period, providing binding rulings and ensuring strict compliance with procedural timelines. The Code also imposes constraints on how bidders and target boards can interact, requiring fairness in the provision of information and avoiding preferential treatment of any single bidder.
Merger Control
The merger control regime in the United Kingdom is enforced by the Competition and Markets Authority (CMA) and is intended to prevent transactions that may significantly impede effective competition. The CMA conducts a two-phase inquiry to assess whether a proposed merger is likely to result in a substantial lessening of competition (SLC). Phase 1 involves a preliminary review of the transaction, which lasts up to 40 working days, during which the CMA may decide to approve the deal unconditionally, approve it subject to undertakings, or refer it to a Phase 2 investigation. Phase 2 is a more detailed examination, typically lasting 24 weeks, and may involve market testing, economic analysis, and stakeholder consultations.
The CMA’s jurisdiction is activated when specific jurisdictional thresholds are met. These include a turnover test, where one of the merging parties has a UK turnover exceeding £70 million, or a share of supply test, where the combined entity holds a share of 25% or more of the supply of particular goods or services in the UK (or a substantial part of it). Notably, merger notification in the UK is voluntary; however, the CMA retains the power to investigate non-notified mergers that fall within its jurisdiction and to impose remedies or unwind transactions even post-completion. This makes early legal and competition analysis essential for acquirers planning to undertake M&A activity in the UK.
5. Legal and Regulatory Framework in Singapore
Governing Laws and Regulatory Authorities
The regulatory framework for Mergers and Acquisitions in Singapore is primarily governed by three major legal instruments. The Companies Act 1967 serves as the foundational legislation, providing the statutory basis for amalgamations and schemes of arrangement, which are widely used mechanisms in M&A transactions. Under the Act, a scheme of arrangement allows companies to reorganize shareholdings or corporate structures with the approval of creditors or shareholders and the sanction of the court. This process is particularly beneficial for complex transactions involving multiple stakeholder classes and has become a mainstay of corporate restructuring in Singapore.
The Singapore Code on Take-overs and Mergers, which is overseen by the Monetary Authority of Singapore (MAS) and administered by the Securities Industry Council (SIC), regulates takeovers involving public listed companies. The Code ensures transparency, integrity, and equal treatment of shareholders during acquisition processes. The SIC has broad investigative and enforcement powers, including the ability to issue rulings, exempt transactions from the Code, and require parties to act in accordance with fair dealing principles. Together with MAS, the SIC maintains a well-regulated and investor-confident takeover environment that aligns with global standards.
The Competition Act 2004, enforced by the Competition and Consumer Commission of Singapore (CCCS), provides the merger control framework. The Act prohibits mergers that would result in, or are likely to result in, a substantial lessening of competition within any market in Singapore. The CCCS has the power to investigate transactions, assess market impact, and impose conditions or remedies if necessary. Though the regime operates on a voluntary notification basis, the Commission plays a critical role in maintaining market competitiveness and safeguarding consumer welfare in the context of consolidation and acquisition.
Takeover Code and Procedures
The Singapore Code on Take-overs and Mergers becomes applicable when an acquisition results in a person or group gaining control of 30% or more of the voting shares in a listed company. Once this threshold is reached, the Code mandates that the acquirer make a mandatory general offer to all remaining shareholders. This ensures that all shareholders have an equal opportunity to exit on the same terms offered to those whose shares were acquired earlier, thereby upholding the principle of fairness and protecting minority rights during a change of control.
A core principle of the Code is the equal treatment of shareholders, which ensures that no group of shareholders is given preferential information or offered better terms. This applies not only to pricing but also to disclosures, timing, and procedural fairness. Furthermore, in the case of voluntary offers, such offers must be either unconditional from the outset or made conditional upon the acquirer obtaining more than 50% of the voting rights. This prevents speculative or disruptive bids and ensures that any acquisition is backed by a sufficient level of shareholder support, thereby enhancing market stability.
Merger Control Regime
Singapore’s merger control operates under a voluntary notification system, meaning that companies are not legally required to notify the CCCS of a proposed merger unless they wish to seek regulatory comfort or foresee competition concerns. Nonetheless, the CCCS retains the authority to initiate investigations if it believes that a completed or proposed transaction may substantially lessen competition. This framework offers flexibility while still enabling regulatory scrutiny of deals that could adversely affect market dynamics.
The jurisdictional thresholds that guide CCCS's assessment include a combined turnover of the merged entity exceeding S$100 million within Singapore, with at least one of the parties generating more than S$50 million in local turnover. If these thresholds are met and there are indicators of market concentration or anticompetitive effects, the CCCS may conduct a Phase 1 or, if necessary, a more detailed Phase 2 investigation. Outcomes may include unconditional clearance, conditional approval with undertakings, or prohibition of the transaction. The system balances regulatory oversight with the efficiency of voluntary compliance.
Practical Dynamics
Singapore’s M&A landscape benefits from a stable, transparent, and efficient legal environment, making it one of the most attractive jurisdictions for corporate transactions in Asia. The country has cultivated a reputation for regulatory clarity, institutional integrity, and investor-friendly procedures. M&A transactions are typically processed efficiently, with proactive engagement from regulators, particularly the SIC and CCCS, who are accessible and responsive to market participants. These factors significantly reduce deal execution risk and timing uncertainty.
Singapore is also a preferred destination for cross-border M&A activity due to its extensive network of double taxation agreements, investment protection treaties, and its role as a financial and corporate services hub in Asia. Its strategic location, sophisticated legal system, and bilingual legal framework make it a natural choice for multinational transactions and regional headquarters operations. These attributes, combined with high levels of corporate governance and judicial reliability, enhance Singapore’s standing in international M&A planning.
Further supporting its robust M&A framework, the Singapore courts are widely regarded as efficient and commercially minded, particularly in their handling of schemes of arrangement under the Companies Act. The judiciary is experienced in complex commercial matters and has a track record of facilitating corporate reorganizations through timely and well-reasoned decisions. Court support for schemes, along with streamlined procedures and high legal certainty, reinforces Singapore’s reputation as a premier M&A jurisdiction.
6. Comparative Analysis
In all three jurisdictions, Sri Lanka, the United Kingdom, and Singapore, the threshold for triggering mandatory takeover obligations is set at 30% of the voting shares of a listed company. Once this level of control is attained, the acquirer is generally required to make an offer to all remaining shareholders. This consistent threshold across the jurisdictions reflects a shared policy objective of preventing creeping acquisitions and ensuring that shareholders are given a fair exit opportunity when effective control of a company changes hands.
The regulatory bodies overseeing M&A transactions vary across the jurisdictions, each with its own structure and areas of authority. In Sri Lanka, the key regulators include the Securities and Exchange Commission (SEC), the Colombo Stock Exchange (CSE), and the Board of Investment (BOI) for transactions involving foreign direct investment. In the United Kingdom, oversight is provided by a combination of the Takeover Panel, which administers the UK Takeover Code; the Financial Conduct Authority (FCA), which oversees disclosure and market conduct; and the Competition and Markets Authority (CMA), which enforces merger control rules. In Singapore, the relevant authorities include the Monetary Authority of Singapore (MAS), the Securities Industry Council (SIC) for takeover supervision, and the Competition and Consumer Commission of Singapore (CCCS), which handles merger control and antitrust issues. This multi-regulator approach is common in most developed jurisdictions but can pose coordination challenges in countries like Sri Lanka, where regulatory roles remain somewhat fragmented.
Merger control regimes also differ substantially. Sri Lanka currently lacks a comprehensive and unified merger control framework, and oversight of competitive impacts is scattered across different authorities without specific thresholds or pre-merger notification requirements. This regulatory gap creates uncertainty and may expose transactions to ex post challenges. In contrast, the United Kingdom has a mandatory merger control regime where the CMA assesses deals that meet specific thresholds, such as turnover or market share, and can block or impose remedies on transactions likely to substantially lessen competition. Singapore, by contrast, operates a voluntary merger notification system; parties may choose to notify the CCCS, especially if a merger raises significant competition concerns, but are not legally required to do so. Nevertheless, the CCCS retains the authority to investigate non-notified mergers post completion, making early competition analysis essential.
When it comes to shareholder protection, each jurisdiction has tailored mechanisms suited to its legal and market environment. In Sri Lanka, the Takeovers and Mergers Code (TOM Code) provides specific protections to shareholders of listed companies, including mandatory offers, pricing rules, and disclosure obligations. However, these protections are limited to listed firms and lack the sophistication and breadth of protections found in more advanced markets. The United Kingdom offers some of the most robust shareholder rights globally, with the UK Takeover Code ensuring equal treatment, full disclosure, and strict procedural timelines, enforced by an active and independent Takeover Panel. Similarly, Singapore imposes mandatory disclosure and fairness obligations under its Takeover Code, with regulatory oversight by the SIC, ensuring that all shareholders are given sufficient information and equal opportunity during takeover bids. These frameworks contribute to strong investor confidence and orderly markets.
All three jurisdictions recognize schemes of arrangement as a legally binding method for facilitating mergers, subject to court approval. In Sri Lanka, the Companies Act No. 7 of 2007 governs such schemes and requires both shareholder approval and judicial sanction, particularly in amalgamations. Similarly, in the United Kingdom, schemes of arrangement are governed by the Companies Act 2006 and must receive approval by a requisite majority of shareholders and then be sanctioned by the High Court. This process is commonly used in public company takeovers as it allows for greater flexibility and binding effect on all shareholders. Singapore, under the Companies Act 1967, follows a comparable model, where schemes of arrangement are frequently used in both domestic and cross-border M&A transactions. Court involvement is a central feature of the process in all three jurisdictions, adding a layer of legal certainty and ensuring the protection of minority shareholder rights.
7. Challenges and Recent Developments
In Sri Lanka, the regulatory framework governing M&A is in the process of evolution. In 2023, the Securities and Exchange Commission (SEC) initiated a public consultation process aimed at updating the Takeovers and Mergers Code (TOM Code). This step was taken in response to increasing market demand for greater efficiency, transparency, and alignment with international best practices. The proposed revisions include measures to enhance the level and quality of disclosures required from offerors, shorten procedural timelines, and introduce more structured rules for market conduct during takeover bids. Despite these efforts, a major regulatory shortcoming remains the absence of a comprehensive and modern competition law. The lack of a consolidated merger control regime, coupled with the absence of a dedicated competition authority, continues to create uncertainty, especially for large or cross-border M&A transactions.
As Sri Lanka seeks to attract foreign investment and improve its business climate, addressing this legal vacuum is critical for building investor confidence and ensuring fair market competition.
In the United Kingdom, the M&A landscape has undergone significant transformation following the UK's withdrawal from the European Union (Brexit). One of the most consequential changes has been the reallocation of merger control powers from the European Commission to the UK’s Competition and Markets Authority (CMA). Post-Brexit, the CMA now has full and independent jurisdiction over transactions that meet UK thresholds, even if they are also subject to scrutiny in the EU. This has led to an increase in regulatory filings and complexity for parties engaged in multinational M&A deals. Moreover, the UK government has adopted a more assertive stance on foreign takeovers, especially in sectors deemed critical to national security, infrastructure, and technology. The introduction of the National Security and Investment Act 2021 has added a new layer of regulatory review, allowing the government to scrutinize and intervene in transactions involving sensitive industries. This reflects a broader global trend of increasing scrutiny on foreign direct investment in strategic sectors.
In Singapore, the regulatory authorities have continued to refine and modernize the country’s M&A oversight regime. In 2022, the Competition and Consumer Commission of Singapore (CCCS) issued updated guidelines on merger procedures, reflecting a more sophisticated and analytical approach to competition review. These revised guidelines emphasize the use of data driven analysis, including economic modelling, market definition tools, and competitive impact assessments. The CCCS also signalled an increased focus on transparency and stakeholder engagement by incorporating public consultation into the merger review process for deals likely to raise significant concerns. These reforms are intended to enhance regulatory clarity, provide businesses with more certainty in structuring deals, and ensure that Singapore remains a competitive and fair marketplace. The changes also underscore the country’s commitment to maintaining a balanced regulatory framework that supports both economic dynamism and consumer welfare.
8. Conclusion
The regulation of Mergers and Acquisitions continues to evolve in response to dynamic global trends, technological disruption, and the increasing complexity of cross-border transactions. Jurisdictions such as the United Kingdom and Singapore have developed comprehensive and sophisticated legal and regulatory regimes that provide clarity, efficiency, and strong investor protections. These frameworks are supported by active and independent regulatory bodies, robust judicial systems, and well-defined competition policies that collectively facilitate smooth execution of M&A transactions while safeguarding market integrity and fairness.
In contrast, Sri Lanka’s M&A framework is still maturing. While recent initiatives by the SEC, including the proposed revision of the TOM Code, demonstrate a willingness to modernize, the absence of a comprehensive competition law and the fragmented regulatory landscape remain significant challenges. There is a pressing need for institutional strengthening, legal harmonization, and clearer procedural guidance to support investor confidence and economic integration. The establishment of a modern competition authority with clearly defined merger control powers would significantly enhance the credibility and effectiveness of Sri Lanka’s regulatory regime.
For businesses, investors, and legal practitioners engaged in M&A activity, a nuanced understanding of each jurisdiction’s regulatory ecosystem is essential. Awareness of local compliance requirements, competition thresholds, and procedural intricacies can substantially influence deal structure, valuation, and execution timelines. As legal frameworks continue to adapt to emerging challenges, cross-jurisdictional analysis such as this becomes increasingly important for structuring legally sound and strategically successful transactions in a globalized economy.
References
- Companies Act No. 7 of 2007 (Sri Lanka)
- Takeovers and Mergers Code of 1995 (as amended), Securities and Exchange Commission of Sri Lanka.
- Securities and Exchange Commission Act No. 19 of 2021
- Companies Act 2006 (UK)
- The City Code on Takeovers and Mergers (UK Takeover Code), issued by the Takeover Panel, United Kingdom.
- Competition and Markets Authority. (2023). Merger Assessment Guidelines. Retrieved from https://www.gov.uk/cma
- Companies Act 1967 (Singapore).
- Securities Industry Council. (2022). Singapore Code on Take-overs and Mergers.
- Competition Act 2004 (Singapore).
- Competition and Consumer Commission of Singapore (CCCS). (2022). Guidelines on the Substantive Assessment of Mergers.
- Relevant regulatory authority websites including:
- Securities and Exchange Commission of Sri Lanka: https://www.sec.gov.lk
- Takeover Panel UK: https://www.thetakeoverpanel.org.uk
- CCCS Singapore: https://www.cccs.gov.sg
- Recent consultation papers and public notices issued between 2023–2024 by the SEC (Sri Lanka), CMA (UK), and CCCS (Singapore).
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