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Minority Shareholder Protection in Cross-Border Mergers: A Must for or an Impediment to the European Single Market?

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Abstract

The main goal of the Cross-Border Merger Directive, adopted in 2005, is to facilitate the mergers of companies registered in different Member States. Therefore, a structure that is highly similar to that of the Third Directive on domestic mergers has been adopted. However, according to Article 4.2 of the Directive, the Member States are free to introduce additional protection mechanisms for minority shareholders opposing the merger. This article discusses whether that provision presents an obstacle to the successful implementation of the Directive and argues that additional minority shareholder protection is indeed necessary, considering the low level of harmonisation among Member States’ company law systems.

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Notes

  1. Preamble 1 of the Cross-Border Merger Directive emphasises this objective by stating: ‘… with a view to the completion and functioning of the single market’.

  2. R. v. HM Treasury and Commissioners of Inland Revenue, Ex p. Daily Mail and General Trust Plc (81/87) ( 1988); Centros Ltd v. Erhvervs- og Selskabsstyrelsen (C-212/97) (1999); Überseering BV v. Nordic Construction Co Baumanagement GmbH (C-208/00) (2002); Kamer van Koophandel en Fabrieken voor Amsterdam v. Inspire Art Ltd (C-167/01) (2003).

  3. SEVIC Systems AG (C-411/03) (2005), at [28]; see also Ugliano (2007), at p. 592. However, it should be noted that the scope of the SEVIC decision was limited to inbound mergers.

  4. Council Directive 78/855/EEC of 9 October 1978 concerning mergers of public limited liability companies.

  5. Directive 2005/56/EC of the European Parliament and of the Council of 26 October 2005 on cross-border mergers of limited liability companies.

  6. Wyckaert and Geens (2008), at p. 41; See also Ugliano (2007), at p. 587.

  7. Cahn and Donald (2010), at p. 634.

  8. See European Commission Press Release (29 November 2005), at http://europa.eu/rapid/press-release_IP-05-1487_en.htm?locale=en (accessed on 4 August 2015).

  9. SEVIC, at [24–28].

  10. Consideration 3 of the Preamble reads as follows: ‘…. None of the provisions and formalities of national law, […], should introduce restrictions on freedom of establishment or on the free movement of capital save where these can be justified in accordance with the case-law of the Court of Justice and in particular by requirements of the general interest and are both necessary for, and proportionate to, the attainment of such overriding requirements’.

  11. Rickford (2005), at p. 1408.

  12. Article 24.2 reads as follows: ‘A Member State may, in the case of the merging companies governed by its law, adopt provisions designed to ensure appropriate protection for minority shareholders who have opposed the merger’.

  13. Wyckaert and Geens (2008), at p. 42.

  14. The CBMD is the first measure to be adopted further to the Action Plan, according to which the two main objectives are fostering competitiveness of EU businesses, with special attention for the cross-border aspect, and strengthening shareholders’ and other stakeholders’ rights. See Press Release, supra n. 8.

  15. Ibid.

  16. Wyckaert and Geens (2008), at p. 41; Mäntysaari (2010), at p. 251; Papadopoulos (2012), at p. 537.

  17. The CBMD requires review by the competent authorities under Article 10.

  18. Ugliano (2007), at p. 613. See also Ventoruzzo (2007), at p. 50.

  19. Rickford (2005), at pp. 1408–1409: ‘It’s very doubtful […] how far MSs can go to add additional impediments to mergers just because they are cross-border […]. Certainly ECJ is likely to scrutinise such provisions very closely for “rule of reason” conformity’.

  20. SEVIC, at [23].

  21. Case C-55/94 Gebhard (1995), at 37.

  22. According to the Gebhard test (ibid.), a different measure for cross-border transactions can only be taken if it is justified by imperative requirements in the public interest. See also Gerner-Beuerle and Schillig (2010), at p. 311.

  23. Fiat SpA, an Italian limited liability company, merged with its Dutch subsidiary Fiat Investments N.V. in October 2014.

  24. Beck and Levine (2004), at p. 31.

  25. Ibid.

  26. Pennington (1995), at p. 283.

  27. Greene (1976), a p. 490.

  28. The most common protective mechanism adopted by Member States where an alteration of articles of association is concerned is the so-called supermajority or ‘special resolution’ requirement, according to which a higher threshold than the simple majority is needed at the general meeting for such a decision to be taken. See Kraakman et al. (2009), at p. 93; See also Ventoruzzo (2007), at p. 59.

  29. Ferran and Ho (2014), at p. 146.

  30. Papadopoulos (2012), at pp. 536–537.

  31. Ventoruzzo (2007), at p. 57; see also Rickford (2005), at p. 1394: ‘A merger may be used as means of migrating the businesses of some or all the participating companies’.

  32. Ibid. A cross-border merger is thought to be an easy way to change the applicable law and enable regulatory arbitrage within the Union; however, this transaction may also be motivated purely by economic reasons, such as the creation of synergies or economies of scale.

  33. The other main drivers behind a cross-border merger are, inter alia, creation of synergies, group reorganisations, reduction of organisational and regulatory compliance costs, tax planning, having a business in more than one Member State, etc. See Bech-Bruun/Lexidale (2013).

  34. These differences include minimum capital requirements, freedom to define the content of the articles of association, rules relating to the board structure and employee participation, etc. See Johnson-Stampe (2010), at p. 27.

  35. This assessment is also backed by an empirical study on 506 merger transactions which shows that better shareholder protection in the acquiring company’s jurisdiction results in higher merger premia in cross-border mergers. See Bris and Cabolis (2008).

  36. Ibid., at p. 28. Differences between Member States’ judicial systems, such as speed of court decisions, can play an important role, affecting share prices and motivating shareholders to approve such a change in applicable law.

  37. Regarding fairness concerns as a basis for minority protection, see Chander (2003), at p. 122 et seq.

  38. Vitali (2006).

  39. Cahn and Donald (2010), at p. 270.

  40. Ibid., at p. 266.

  41. Ventoruzzo (2015). It should be noted that loyalty shares may not always constitute a class of shares, as in the example of Italy.

  42. Ibid.

  43. For instance, UK Companies Act 2006 S 620; German Aktiengesetz para. 182(2).

  44. Ferran and Ho (2014), at p. 130.

  45. See Reynolds (1996), at p. 556.

  46. Pennington (1995); Ferran and Ho (2014), at p. 149.

  47. Vitali (2006), at p. 19.

  48. Limiting the scope of class rights through restrictive interpretation is more common in common law countries, such as the UK, whereas exclusive statutory listing is found more often in civil law countries.

  49. Wyckaert and Geens (2008), at p. 40.

  50. Boros (1995), ch. 2.

  51. Mäntysaari (2010), at p. 250.

  52. Ventoruzzo (2007), at p. 47. It should be noted that relative attractiveness is determined from the perspective of all interested parties, including controlling shareholders, management and minority shareholders.

  53. See Mäntysaari (2005), ch. 4. Especially in the case of non-listed companies, the flexibility in structuring the articles of association is significant.

  54. Ibid., at p. 82.

  55. Wyckaert and Geens (2008), at p. 49; see also Rickford (2005), at p. 1413.

  56. See Ventoruzzo (2007), at p. 69.

  57. Article 9.1 states the following: ‘After taking note of the reports referred to in Articles 7 and 8, the general meeting of each of the merging companies shall decide on the approval of the common draft terms of cross-border merger.’; Wyckaert, and Geens (2008), at p. 41.

  58. Ibid.; see also Rickford (2005), at p. 1412.

  59. See Paunio (2009).

  60. Ibid., at p. 1474.

  61. For the importance of the predictability of the governing law from creditors’ perspective, see Eidenmüller (2005), at p. 429. See also Hansmann and Kraakman (2000), at p. 11. The shareholder primacy approach firstly necessitates protection of non-controlling shareholders, absent which companies will have difficulty raising capital.

  62. La Porta et al. (2002), at p. 1150.

  63. Ibid.

  64. La Porta et al. (1997), see also Bris and Cabolis (2008), at p. 632.

  65. Jensen and Meckling (1976), at p. 311.

  66. La Porta et al. (2002), at p. 1151.

  67. Jensen and Meckling (1976), at p. 311.

  68. Bris and Cabolis (2008), at p. 632.

  69. UK Companies Act 2006 S 168 states that the general meeting can remove directors at any time without any cause.

  70. See La Porta et al. (2002), at p. 1152.

  71. Ibid. See also Hansmann and Kraakman (2000), at p. 61. Devices used by expropriating controlling shareholders usually involve ‘inefficient investment choices and management policies’.

  72. Pannier (2005).

  73. Johnson et al. (2000) and Coffee (1999).

  74. La Porta et al. (2002), at p. 1155.

  75. Ibid., at p. 1159. According to the authors, in those states where investor protection is lower, control gains greater value and results in a higher premium to be paid, decreasing the likelihood of control transactions and causing a more concentrated ownership structure so as to dominate the markets.

  76. However, it should be noted that some empirical studies show that the market values such investors’ legal protection only when the level of protection increases following the transaction, together with a parallel increase in share prices. According to this view, share prices will remain unaffected even if after the change of applicable law the level of investor protection decreases. See Bris and Cabolis (2008), at p. 631.

  77. In states with weaker property rights and investor protection, capital is mainly raised via internal channels as external capital is limited and expensive. See Baums and Scott (2003), at p. 7.

  78. See Wyckaert and Geens (2008), at p. 50. See also Ventoruzzo (2007).

  79. See Ferran (2004). See also Miller (1997).

  80. Note that the Third Directive on domestic mergers only applies to public limited liability companies, leaving the regulation of merger transactions of private companies to the national legislator. See Ugliano (2007), at p. 600; Papadopoulos (2012), at p. 534. See also Rickford (2005), at pp. 1400–1403.

  81. See Mäntysaari (2005), ch. 3. The author refers to ‘piece-meal harmonisation’ in order to define this selective harmonisation project. See also Hansmann and Kraakman (2000), at p. 28.

  82. Ventoruzzo (2015), at p. 17.

  83. The information document can be found at http://www.fcagroup.com/en-US/investor_relations/merger_of_fiat_spa_with_and_into_FCA_NV/Documents/Equivalent_Document_with_Annexes.pdf (accessed 27 July 2015).

  84. Ventoruzzo (2015), at p. 3. See also The Economist, ‘Company headquarters: here, there and everywhere’, 22 February 2014, at http://www.economist.com/news/business/21596976-why-some-businesses-choose-multiple-corporate-citizenships-here-there-and-everywhere (accessed 26 July 2015).

  85. Carbonara (2014).

  86. As it is called by the FCA group: http://2014annualreport.fcagroup.com/en/report-operations/corporate-governance/loyalty-voting-structure (accessed 26 July 2015).

  87. Ibid. See also Carbonara (2014).

  88. Ventoruzzo (2015), at p. 8. See also Bolton and Samama (2013).

  89. Gilson and Gordon (2003). See also Rickford (2006), at p. 73. According to Rickford, even though the same result can be achieved through other means, the disproportionate voting structure allows controlling shareholders to extract more private benefits of control more easily and at a lower cost.

  90. Exor SpA holds 29.19% of the share capital and 44.3% of the voting rights of FCA as of 28 July 2015. Exor is the investment vehicle of the Agnelli family, who controls Exor SpA. See https://www.exor.com/ and http://www.ft.com/cms/s/0/eebb9e50-24ba-11e5-9c4e-a775d2b173ca.html#axzz3h6LlaJoM (accessed 28 July 2015).

  91. FCA’s shares are traded at both the New York Stock Exchange and the Milan Bourse. See http://www.reuters.com/article/2014/10/07/us-fiat-spa-chrysler-idUSKCN0HW0CZ20141007 (accessed 27 July 2015).

  92. The break-through rule, which aims at eliminating this effect of multiple voting rights, has been made optional under Article 11 of the Takeover Directive and has not been implemented by the Netherlands. See Kotlarik (2008), at p. 29.

  93. For example, Belgium, Germany and Spain do not allow different classes of shares with disproportionate voting rights, whereas the laws of France, the Netherlands and the United Kingdom do.

  94. See Ventoruzzo (2015), at p. 9.

  95. It is worth noting that Italy allowed multiple voting rights for shares held for a continuous period of two years following the corporate emigration of the Fiat group, one of its biggest national champions, through the ‘Development Decree’ that was approved in August 2015. This decision has been defined as ‘both the cause and consequence of regulatory competition in the EU’. See Ventoruzzo (2015), at p. 41.

  96. For a detailed comparison between shareholder rights under Italian and Dutch law, see the FCA Prospectus, at p. 236 et seq., http://www.fcagroup.com/it-IT/investor_relations/merger_of_fiat_spa_with_and_into_FCA_NV/Documents/Bookmarked_FCA_Prospectus.pdf?redirectFromFiatspa=1 (accessed 5 August 2015).

  97. For example, the length of court litigation in Italy may constitute a concern for a shareholder of a company subject to Italian law. See Chase (1988) and Felli et al. (2008), ch. 9. See also Mäntysaari (2005), ch. 4.

  98. Bech-Bruun/Lexidale (2013), at p. 5.

  99. Ibid.

  100. It has been stated that the appraisal rights may contradict the freedom of movement, rendering the change in applicable law practically impossible. See Arlt et al. (2004), at p. 13.

  101. A similar approach has been taken by the European Commission concerning the proposed 14th Company Law Directive on the transfer of seat. See European Commission, Impact assessment on the Directive on the cross-border transfer of registered office (December 2007), at http://ec.europa.eu/internal_market/company/docs/shareholders/ia_transfer_122007_part1_en.pdf (accessed on 7 August 2015).

  102. For example, the United Kingdom did not introduce any additional measure whereas Germany and Italy did.

  103. In their study, Bech–Bruun argues that the under-harmonisation regarding the nature of the protection to be adopted by Member States constitutes an obstacle to the improvement of the CBMD’s implementation and suggests either full harmonisation in the area, or specification by the CBMD of an array of options for the states. See Bech-Bruun/Lexidale (2013), at pp. 10–13.

  104. Baums and Scott (2003), at p. 13.

  105. The German legislator has considered the company law rules on minority protection to be insufficient in the group of companies context. See Cahn and Donald (2010), at p. 682. See also Zhao (2011) and Sargent (1985).

  106. §122i. It should also be kept in mind that dissenting shareholders, as in a domestic merger, have the right to withdraw from the company. See De Vries (2010), at p. 193.

  107. Ibid.

  108. See Bebchuk and Kahan (2000).

  109. Mäntysaari (2005), at p. 250. Article 22 of the Third Company Law Directive and Article 17 of the CBMD.

  110. Wyckaert and Geens (2008), at pp. 44–45.

  111. See Ventoruzzo (2015), at p. 18.

  112. For criticism of this approach taken by the French legislator see, L. Boisseau, ‘Fusions trans-frontalières: les minoritaires sans protection’, Les Echos, 13 April 2015, at http://www.lesechos.fr/journal20150413/lec2_finance_et_marches/0204293587266-fusions-trans-frontalieres-les-minoritaires-sans-protection-1110593.php#> (accessed 2 August 2015).

  113. Papadopoulos (2012), at p. 538. See also pp. 531-532 for other complications that may arise.

  114. Bech-Bruun/Lexidale (2013), at p. 12.

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    Gökçe Kurtulan

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This article is a developed and updated version of the dissertation that the author wrote during the LLM programme at the London School of Economics and Political Science. I would like to express my thanks to Edmund Schuster for his support and helpful comments. I would also like to thank Rainer Kulms for his valuable suggestions and Suzanne Habraken for her linguistic editing of the original text.

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Kurtulan, G. Minority Shareholder Protection in Cross-Border Mergers: A Must for or an Impediment to the European Single Market?. Eur Bus Org Law Rev 18, 101–121 (2017). https://doi.org/10.1007/s40804-017-0061-7

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