反收购的规制模式与我国的立法选择

Models of Anti-takeover Law and China' Preference

公司收购是一种市场行为,因此反收购措施也应该视为一种商业运作。在反收购的法律规制中,可资借鉴的有英美两种模式。我国反收购措施的法律尚不完备,需要在具体制度上加以完善。

takeover is an activity in market and anti-takeover should be regarded as a measure of business. There are two types of model in the legislation of anti-takeover England model and American model. We should learn from them to make our law perfectly since the law of anti-takeover need to modify and perfect.