Mergers & Acquisitions Comparative Guide

1 Deal structure

1.1 How are private and public M&A transactions typically structured in your jurisdiction?

Private merger transactions dominate the M&A market in the United Arab Emirates, representing a significant proportion of overall activity.

Private mergers in the United Arab Emirates usually take two forms: share sales and asset sales.

Share sales: It is becoming increasingly common for share sales to be structured through a holding company incorporated in a common law jurisdiction such as the Abu Dhabi Global Market (ADGM) or the Dubai International Financial Centre (DIFC). For background, the ADGM and the DIFC operate as independent jurisdictions separate from the onshore United Arab Emirates. They follow a common law framework and disputes within these jurisdictions are adjudicated in English, based on English law principles.