On a share purchase, the default position is that the identity of the target company remains the same before and after the sale; it is simply ownership of the target that changes. This means the employing entity remains the same and employees stay where they are.
On an asset purchase, employees may become employed by the buyer. In the UK this takes place under the Transfer of Undertakings (Protection of Employment Regulations) 2006 (TUPE), which is derived from the EU Acquired Rights Directive (‘ARD’). Countries in Europe have their own national legislation implementing the ARD, similar to but not always the same as TUPE. Some countries outside Europe (Chile, Argentina, Brazil and Singapore, to name a few) have their own rules about automatic transfer of employment/succession of employer.
TUPE provides that where there is a transfer of assets amounting to “an economic entity which retains its identity”, any of the transferor’s employees who are assigned to that economic entity will transfer with it. This would include a business sold as a going concern (including after a share purchase)....
Russia's Defense Ministry is reporting alleged battlefield successes on Max, but some of its claims lack evidence. Even Russian military bloggers are questioning claims that Ukrainian forces have ...