TUPE, Article 23¹, and Beyond: Employee Transfer Risks in Cross-Border M&A

Cross-border M&A deals tend to focus on valuation, structure, and timing. Fair enough. Those are visible and measurable. What often receives less attention, at least early on, is employee transfer risk. And yet, in many jurisdictions, employees do not simply “move” because a deal closes. Their rights are protected by local labor laws. In some cases, […]