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The rules on conflict of laws are the cornerstones of the new European Directive on Takeovers. The following article will critically, but overall positively evaluate their solutions by way of comparison with the scope and applicability of domestic takeover laws in Germany, France, the UK and the USA, concentrating in various manners on the real seat of the target, on the place of its listing or on the residence of the shareholders

The Rules on Conflict of Laws in the European Takeover Directive