Comparison and Evaluation of the Regulatory Frameworks of the U.K., Germany and China

Abstract

AbstractThis chapter compares and evaluates the protection of the public interest, the interests of corporate stakeholders and other societal interests in the three jurisdictions based on the discussions in Chaps. 2–5. It first analyses the similarities and differences in the scope of relevant societal interests that are protected as well as the specific protection mechanisms under the government regulation (including the competition law, FDI screening law, takeover law, and corporate law) and private regulation (the national corporate governance code) of takeovers in the three jurisdictions. Following that, it conducts a normative evaluation of the roles of the protection mechanisms in protecting the relevant societal interests by reviewing their advantages and problems in dealing with the market failure problems that may be caused as a result of takeovers.