This month has seen a post-merger notification regime enter into force in Cambodia, the publication of the Draft Merger Regulations in India, including guidance on the deal value threshold, the Luxembourg government providing further information in relation to the legislative bill to introduce a merger control regime, amendments to the Competition law in Moldova entering into force and the Ukrainian Parliament publishing amendments to the country’s competition law framework. Cambodia—new merger control thresholds enter into force In our monthly update for March 2023, we highlighted that the Cambodian Competition Commission (CCC) issued various new regulations introducing a post-merger notification regime. On 6 September 2023, the merger control regime came into force. A transaction requires notification in Cambodia where: • the combined Cambodian assets of all parties in the previous financial year exceeds KHR 340bn (approx. €78.8m/US$83.1m); • the combined Cambodian turnover or revenue of all parties in the previous financial year exceeds KHR 270bn (approx. €62.7m/US$66m) or KHR 120bn (approx. €27.8m/US$29.3m) respectively; or • the total operating cost of the proposed transaction exceeds KHR 41bn (approx.

This month has seen the deal value thresholds come into force in India. India—deal value thresholds enter into force In 2023, we highlighted significant changes to the Indian merger control regime under the Competition (Amendment) Act 2023 (Amendment Act), which reformed the Competition Act 2022. On 10 September 2024, the merger control provisions of the Amendment Act came into force. In addition, the Competition Commission of India (CCI) published the Competition Commission of India (Combinations) Regulations 2024 (Revised Combination Regulations). One of the key changes brought in by the merger control reforms is the deal value threshold. This has been introduced as an additional jurisdictional threshold. The existing asset/turnover based thresholds continue to exist alongside the new deal value threshold. Under the deal value threshold, a mandatory filing will be required if: • the transaction value exceeds IND 20bn (€223.9m/US$ 238.1m), and • the target has substantial business operations in India If the transaction meets both thresholds, it will not be eligible for the target-based exemption. In relation to determining the deal value of the transaction, the CCI

This month has seen the Australian Government launch a consultation on the Exposure Draft of the Australian Competition and Consumer Commission’s mandatory notification waiver form, the New Zealand Government announce major merger control reforms, and the Uganda Government publish the Competition Regulations 2025, establishing a merger control regime. Australia—Treasury consults on Exposure Draft of ACCC mandatory notification waiver form On 3 September 2025, the Treasury published an Exposure Draft Instrument setting out the Australian Competition and Consumer Commission’s (ACCC) proposed mandatory notification waiver form. Consultation on the draft closed on 16 September 2025. Background From 1 January 2026, mergers that meet the merger thresholds must be notified to the ACCC, unless an exemption applies. Failure to notify will render a transaction automatically void. However, the ACCC will be empowered to grant waivers from notification, allowing certain transactions to proceed without undergoing the full notification process. Waiver applications Notification waivers are voluntary and available where transactions are unlikely to raise competition concerns requiring further investigation. The application fee is AUD 8,300 compared with AUD 56,800 for a phase

This month has seen transitional rules being issued ahead of the introduction of the new pre-closing merger control regime in Argentina, amendments to Australia’s merger control regime refining the notification, control and clearance rules come into force, the Belgian Competition Authority conditionally closed its Towercast investigation into the Live Nation/Pukkelpop merger following commitments, the Government of Bermuda launches a consultation on new competition rules, including a regime for reviewing certain mergers and acquisitions in seven essential sectors, the Danish Competition Council conditionally clears the Uber/Dantaxi merger after a phase II investigation in its first below-threshold call-in decision, the amended merger control thresholds come into force in France, the Irish Competition and Consumer Protection Commission launch a phase 2 investigation in the Uniphar/TouchStore merger following a below-threshold call-in, Dutch call-in powers move closer as the House of Representatives approves an amended bill, a new mandatory merger control regime comes into force in Timor-Leste, the UK Competition and Markets Authority updates its Merger Assessment Guidelines on the assessment of rivalry-enhancing efficiencies, and Vietnam proposes new exemptions from merger

This month has seen clarification issued in relation to the temporary increase in the notification thresholds in the Philippines, clarification issued in Indonesia in relation to asset acquisitions, foreign-to-foreign transactions and the simplified procedure, and an extension to a consultation on proposed amendments to the merger control regime in Namibia. In addition, we have launched a new topic covering multi-jurisdictional FDI control. Philippines—notification thresholds increased for two years The Philippines Competition Commission (PCC) has issued rules clarifying the application of the increased notification thresholds under the Bayanihan to Recover As One Act, which introduced an exemption from the notification requirement for two years where the value of the transaction is less than PHP 50bn. The PCC has clarified that now, until 15 September 2022, transactions will require notification to the PCC (with closing to be suspending pending clearance) where: • at least one party (including ultimate parent entities) has either annual turnover in, into and from the Philippines or assets in the Philippines in excess of PHP 50bn (approx. €870.9m/US$1,026.6m), and • the value of the transaction

This month has seen the FTC’s: reinstatement of a decade-old policy requiring acquiring parties subject to an FTC merger enforcement order (ie consent decree) to obtain prior approval for any future transaction for at least 10 years, withdrawal of vertical merger guidelines and commentary, and adoption of changes to streamline its second request process, Hungary introduce a merger review exemption for state-owned capital funds and amendments to the notification thresholds in Kuwait and an announcement from Egyptian Competition Authority revealing its intention to enforce post-merger obligation requirements and proposed amendments to the merger control regime in Taiwan. United States—FTC votes to withdraw Vertical Merger Guidelines and Commentary On 15 September 2021, the Federal Trade Commission (FTC) held its third open meeting under the new leadership of Chair Lina Khan. As expected, the FTC voted to withdraw approval of: (i) the Vertical Merger Guidelines (Guidelines), issued jointly with the Department of Justice (DOJ), and (ii) the FCA’s Vertical Merger Commentary. The vote was 3-2 along party lines. On the same day, the DOJ issued a statement announcing

In legal practice, “International Monetary Fund” (IMF) refers to the intergovernmental financial institution whose treaty‑based rules, lending and data shape sovereign finance, SDR‑linked obligations and aspects of public international law relevant to UK and Irish matters. It is established by the IMF Articles of Agreement (a multilateral treaty). In the UK and Ireland, membership, funding (quota/allocations) and privileges and immunities are given domestic effect through Bretton Woods/implementing legislation and orders; there is no free‑standing domestic statutory definition beyond that treaty framework.Key legal features and uses:- Balance‑of‑payments assistance to member states, typically with programme conditionality.- Allocation and daily valuation of Special Drawing Rights (SDRs), widely referenced in UK and Irish statutes and international conventions (for example, liability limits in transport and maritime regimes).- Surveillance (Article IV) and policy assessments relevant to sovereign debt restructuring, exchange controls and public finance advice.- De facto “preferred creditor” status considered in restructuring strategies and enforcement risk analysis.- Treaty‑based privileges and immunities affecting litigation, service, disclosure and execution against IMF property.Across England & Wales, Scotland, Northern Ireland and Ireland, usage is broadly consistent: courts and practitioners treat the IMF as an international organisation operating under its Articles of Agreement, with SDR references and immunities implemented domestically.

The international movement of capital rules should be considered whenever: • any non-UK tax resident subsidiary (referred to in this Practice Note as a foreign subsidiary or foreign company) is controlled directly or indirectly by a UK tax resident company, and • either: ◦ the foreign company's shares or debentures are issued or transferred, or ◦ the foreign subsidiary becomes or ceases to be a controlling partner in a partnership (wherever that partnership is established) In these cases, the reporting body (usually the top UK tax resident company of a group of companies who, alone or taken together with others, controls the foreign subsidiary) must submit a report to HMRC unless the event or transaction is: • excluded, or • worth no more than £100m (taking into account the value of any events or transactions which are part of the same series of events or transactions) The international movement of capital rules: • are found in Schedule 17 to the Finance Act 2009 (FA 2009), and • the International Movement of Capital (Required Information) Regulations

This Practice Note contains a table of international financial sanctions lists with links to the various lists and the regulatory bodies responsible for them, where possible. ​​Country ​​Regulatory body ​​Sanctions List (Links to sanctions lists are provided, where publicly available) ​​Including Multinational United Nations United Nations Security Council Consolidated List Persons and entitiesEmbargoed countries Multinational World Bank World Bank Listing of Ineligible Firms and Individuals Persons and entities EU Sanctions European Council EU Sanctions Map Persons and entitiesEmbargoed countriesSpecial measures (Russia) Argentina Superintendencia de Seguros de la Nación (SSN) Superintendencia de Seguros de la Nación Liquidación Persons and entitiesEmbargoed countries Argentina Comisión Nacional de Valores Comisión Nacional de Valores Persons and entitiesEmbargoed countries Argentina Unidad de Información Financiera Unidad de Información Financiera Persons and entitiesEmbargoed countries Australia Australian Government Department of Foreign Affairs and Trade Department of Foreign Affairs and Trade Persons and entitiesEmbargoed countriesSpecified Entities (Iran) Australia Australian

an organisation and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries. Examples would be the North Atlantic Treaty Organization (NATO), the United Nations (UN) and other multi-country organisations.

This Practice Note considers issues arising in multi-jurisdictional outsourcing arrangements, including offshore and nearshore transactions. Outsourced service provision is an established business strategy in most developed economies of the world and is increasing its prevalence in developing countries. This Practice Note considers the following key issues specific to multinational or offshore outsourcing arrangements: • Initial considerations • Deal structures • Payment and invoicing • Benchmarking • Governing law • Forum for resolving disputes • Jurisdiction • Operational issues • Data protection • Personnel • Tax considerations • Corruption, slavery and ethical issues • Termination For an outsourcing agreement suitable for use in international transactions, see Precedent: Outsourcing agreement—long form. See also Precedent: Offshore IT outsourcing—training materials. For more general guidance on contracting internationally, see: International contracts—overview. For jurisdiction specific guidance, see: Doing business in key global jurisdictions—overview and Lexology Panoramic: Outsourcing. Initial considerations The growth in international outsourcing has been facilitated by suppliers having developed credible regional delivery centres that can deliver the outsourced services on a cross-border basis so as to meet local requirements. An international outsourcing transaction

Instead of, or in addition to, filing a national patent application at a national patent office (eg a GB patent application at the UK Intellectual Property Office (UK IPO)), or a regional patent application at a regional patent office (eg a European patent application at the European Patent Office (EPO)), an international patent application can be filed under the Patent Cooperation Treaty (PCT). This Practice Note provides an overview of the main provisions of the PCT and the process for filing an international patent application. For more information about applying for a GB patent at the UK IPO, see Practice Note: Patent applications—how to obtain patent protection in the UK. For a list of the regional patent offices, see here and for more information about European patent applications at the EPO, see Practice Note: European patent—application procedure. The Patent Cooperation Treaty (PCT) The PCT, which was established in 1970, assists applicants in seeking patent protection internationally for their inventions. The PCT has been ratified by over 150 countries, including the UK. For a list of