A public-to-private transaction (or P2P) is one in which a bidder buys a public listed company, taking it into private ownership. A P2P financing often involve complexities that do not apply in other types of financing – in particular those flowing from the relevant takeover regulations, but also from company law requirements specific to public companies. Lenders active in P2P financings across Europe need to be mindful of how this underlying legal framework differs across European jurisdictions. In this article, we focus on four areas in which these jurisdictional variables can affect the position of a P2P lender.

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