Same-same, only different – key differences in law and practice affecting private share deals in Australia and China

In 2014, mainland China's investment in Australia totalled $64.5 billion and Australia's investment in mainland China reached almost $58 billion. Australia maintained its position as the second largest recipient country of aggregated global mainland Chinese direct investment between 2007 and 2014, behind the United States in first position. And in 2014, mainland China was Australia's 6^th leading investment destination country behind the United States, the United Kingdom, New Zealand, Japan, and Germany. In this context, there has been a substantial amount of mergers and acquisitions (M&A) activity between Australia and China, not to mention the activity that has been channelled through investment vehicles in jurisdictions such as Singapore and Hong Kong.