UK Employment Law Risks In Cross-Border M&A

By Richard Moore (June 7, 2018, 1:26 PM EDT) -- The acquisition of U.K.-based companies or assets will often give rise to employment law considerations that are unfamiliar to U.S. buyers. Our respective approaches to a number of fundamental employment principles differ substantively — for example, the contrast between "at-will" employment in the U.S. and unfair dismissal protection in the U.K. In addition, U.K. employment law brings a variety of concepts to the table that can seem counterintuitive to the U.S. market, such as the automatic transfer of employees on an asset sale.

U.K. employment law has developed in myriad ways and continues to do so. In terms of issues to...

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