Competition Law

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Archive for the ‘Mergers’ Category

Sims’ Law Council speech

Posted by Julie Clarke on 12 August 2013

ACCC Chairman, Rod Sims’ address to the Law Council of Australia’s Competition and Consumer Workshop is now available from the ACCC website. In it, he provides a tribute to Ron Bannerman, sets out regulatory issues for 2013, discusses the review of the Merger Review Process Guidelines, talks about compliance and enforcement, addresses some consumer issues and discusses ACCC engagement in the region.


In relation to mergers Sims noted that the ACCC’s ‘main focus will be on a real world understanding of market structure and import competition, entry barriers, countervailing power and the overall competition process’ rather than ‘complex theories and detailed modelling’. He also noted that the ACCC was ‘close to finalising the revised Process Guidelines’, noting one of the key changes was to move away from the practice of setting 6-8 week standard review periods for all public merger reviews, noting that in complex cases reviews will often take longer than eight weeks and that in some cases review periods will be extended to coordinate reviews with other agencies. Sims also acknowledged concerns about the timeframes for publishing public competition assessments, noting that the ACCC has ‘undertaken steps internally to streamline our processes for preparing PCAs’ and will aim to publish within 30 days of announcing its final decision.

Compliance and enforcement

Sims noted that the ACCC wins around 80 per cent of cases it takes. Focus is consumer law, but Sims also focussed a lot on the ‘largest penalties for cartel conduct in the history of the ACCC’ – this is cumulatively and relates to the international air cargo cartel, for which many regulators can claim success. Sims also noted there had been five competition proceedings instituted in the 2011-2012 financial year (four alleging cartels and one (against Visa) alleging misuse of market power and exclusive dealing). Once again Sims promised more competition cases in the coming year. Sims also spoke about the ACCC’s review of its immunity policy for cartel conduct, which he anticipates will be finalised in the coming months, with a discussion paper to be released in September.

International engagement

Sims described the ACCC’s efforts to maximise engagement in the Asian region and noted that the ACCC will host the ICN annual conference in 2015.

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Creeping acquisition bill back in Parliament

Posted by Julie Clarke on 15 June 2011

In 2010 the Government announced it would introduce laws to deal with ‘creeping acquisitions’.  In May 2010 they introduced a bill which they claimed would do this (see my blog post discussing the proposed amendments).  That bill was considered by the Senate Economics Legislation Committee which, on 15 June 2010 (precisely a year ago!) recommended that it be passed.  The bill subsequently lapsed as a result of the 2010 Federal Election.

Today the Government re-introduced this bill (in the same terms as far as mergers are concerned – the bill also deals with unconscionable conduct).  View also David Bradbury’s second reading speech.

More to follow …

Posted in Legislation (TPA/CCA), Mergers | Tagged: , , , | Leave a Comment »

Metcash v ACCC

Posted by Julie Clarke on 24 November 2010

The fight is on.

Metcash have announced that they will proceed with its planned takeover of Franklins, despite the ACCC last week announcing that it would oppose the acquisition (view press release and informal merger decision).  Yesterday’s media release stated, in part:

Metcash Trading Limited has notified the ACCC that, in not fewer than 5 business days from today, it intends to take further steps to proceed with the Proposed Transaction.

This is the first such challenge since the Toll Holdings showdown in 2006 (which was ultimately resolved with undertakings) and AGL in 2003, which was successful in its Federal Court challenge (in which it sought and was given a declaration that its merger would not contravene s 50 (see AGL case).  I can’t wait.

Thanks to the usual suspects (Nationals Senator Ron Boswell and independents Nick Xenophon and Steve Fielding, supported by the opposition) the Senate Economics Committee is also going to consider the ACCC’s decision in this (see Senate Hansard, 23/11/2010 at p 37) – this is an extraordinary referral to the Committee and it’s not entirely sure what it is designed to achieve, other than political point scoring and an undermining of the ACCC’s independence.  Submissions are due by 29 November (less than a week, which just adds to the  farcical nature of this inquiry).  The report is due on 17 December 2010 (because it takes non-expert Senators much less time to get their head around the complex law and economics issues associated with mergers than the expert lawyers and economists at the ACCC).  Another extraordinary waste of time and money.

Much more to follow on this one.

There’s plenty of media on this, including:

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US agencies release new merger guidelines

Posted by Julie Clarke on 20 August 2010

The US Federal Trade Commission and Department of Justice today announced the release of new horizontal merger guidelines. These replace the 1992 merger guidelines and follow the release of  draft revised guidelines in April this year. Comments/submissions on the draft guidelines can be viewed here.

The press release lists key changes since the 1992 Guidelines (FTC Press Release / DOJ Press Release) – in particular, the new guidelines:

* Clarify that merger analysis does not use a single methodology, but is a fact-specific process through which the agencies use a variety of tools to analyze the evidence to determine whether a merger may substantially lessen competition.

* Introduce a new section on “Evidence of Adverse Competitive Effects.” This section discusses several categories and sources of evidence that the agencies, in their experience, have found informative in predicting the likely competitive effects of mergers.

* Explain that market definition is not an end itself or a necessary starting point of merger analysis, and market concentration is a tool that is useful to the extent it illuminates the merger’s likely competitive effects.

* Provide an updated explanation of the hypothetical monopolist test used to define relevant antitrust markets and how the agencies implement that test in practice.

* Update the concentration thresholds that determine whether a transaction warrants further scrutiny by the agencies.

* Provide an expanded discussion of how the agencies evaluate unilateral competitive effects, including effects on innovation.

* Provide an updated section on coordinated effects. The guidelines clarify that coordinated effects, like unilateral effects, include conduct not otherwise condemned by the antitrust laws.

* Provide a simplified discussion of how the agencies evaluate whether entry into the relevant market is so easy that a merger is not likely to enhance market power.

* Add new sections on powerful buyers, mergers between competing buyers, and partial acquisitions.

Naturally, the new guidelines already have some critics, including Republican and FTC  Commissioner J Thomas Rosch who, although concurring with the issuance of the guidelines, criticised them for not living up to their promise of being a “complete and accurate description of what our enforcement staff considers in merger investigations and that they will be a helpful guide to courts”.  View Commissioner Rosch’s press release here and further commentary here.

Australia also recently (November 2008) adopted new merger guidelines which replaced its 1999 Merger Guidelines.

Posted in Competition Policy, International, Mergers, United States | Tagged: , , , | Leave a Comment »

Creeping Acquisitions Bill Introduced

Posted by Julie Clarke on 27 May 2010

The Competition and Consumer Legislation Amendment Bill was introduced into Parliament today.  It includes the following key amendment to the competition law provisions:

(1) replacing the words ‘a market’ in section 50(1) with ‘any market’

(2) Removing the requirement that a market, for purposes of the merger provision, be a ‘substantial’ market, by removing the word substantial from subsection 50(6)

The Government claims that this will address some of the concerns raised about creeping acquisitions.

Detail on the changes

Subsection 50(1)

The existing s 50(1) provides:

A corporation must not directly or indirectly:

(a) acquire shares in the capital of a body corporate; or

(b) acquire any assets of a person;

if the acquisition would have the effect, or be likely to have the effect, of substantially lessening competition in a market.

The bill proposes to amend the last two words from ‘a market’ to ‘any market’. This, the EM explains (at para 1.33)  is to ‘clarify the ability of the ACCC or a court to consider multiple markets when assessing mergers’ and to ‘prevent businesses from being able to challenge a decision that a proposed merger or acquisition would, or would be likely to, substantially lessen competition in a market in breach of section 50, on the grounds that the lessening of competition identified was in one or more markets other than the primary market in which the merger or acquisition would occur.’

Subsection 50(6)

The existing provision provides that, for purposes of s 50:

market means a substantial market for goods or services in:

(a) Australia; or

(b) a State; or

(c) a Territory; or

(d) a region of Australia.

The bill proposes to remove the word ‘substantial’. The government claims that the current provision is unclear about whether or not the market definition extends to ‘local’ markets and is also unclear on just how ‘substantial’ a market must be to be caught. In particular, they claim (at para 1.28 of the EM) that removing the word substantial will ‘remove the risk … that a court may in the future adopt the view that the substantiality of a market should be determined with reference to Australia as a whole.’ The EM goes on to state that the ‘amendment will also remove doubts regarding the ACCC’s ability to examine markets where creeping acquisitions concerns may arise in the future’.

They are the proposed changes in a nutshell.  More detail to follow soon.

Note: Dr Emerson’s second reading speech is now available.

Posted in Legislation, Mergers | Tagged: , | 1 Comment »

Senate Committee rejects amendments to merger laws

Posted by Julie Clarke on 13 May 2010

The Senate Economics Legislation Committee has recommended that the Trade Practices Amendment (Material Lessening of Competition – Richmond Amendment) Bill 2009 be rejected.

The Bill was introduced by Senator Nick Xenophon and drafted by Associate Professor Frank Zumbo.  According to Senator Xenophon it was a response to an event occurring in West Richmond, Adelaide, involving Woolworths’ attempt to purchase a service station site next to a small independent site run by ‘Mr Fares’.  Of course, this has nothing to do with the content of the Bill, which relates to mergers, but that didn’t stop the Bill’s proponents from using this example as justification for the Bill (the Senate Committee correctly noted that the ‘anticipated’ conduct complained of would relate to predatory pricing not creeping acquisitions, despite claims to the contrary by Zumbo – and that, ironically, the Bill is likely to hurt Mr Fares by removing his ability to sell his business asset to larger competitor).

The Bill itself was designed to do two things:

  • lower the threshold for prohibited mergers from those that substantially lessen competition to those that materially lessen competition
  • address creeping acquisitions by preventing a corporation with substantial market share from merging or acquiring shares/assets which would have the effect of lessening competition in a market (no ‘substantial’ or ‘material’ lessening required)

Are Australia’s current merger laws too permissive?

Before considering their view on the Bill itself, the Committee considered the claim by leading proponent of the Bill, Frank Zumbo, that the ACCC approves 97% – or nearly all – mergers and that this proved Australia’s merger laws were too permissive.  The Committee rejected this claim, finding that it was misleading because it excluded mergers not assessed because they do not substantially lessen competition and those not proposed because they clearly do have that effect.  As a result, it did not accept that the 97% approval figure was accurate or that it proved that Australia’s merger regime was too permissive.

Lowering the merger threshold

On the first point the Committee (Xenophon dissenting) held that alteration of the merger test would generate uncertainty when there was no sound evidence suggesting a problem with the current bill.  They also did not accept that the different wording would necessarily lower the threshold as Zumbo had claimed.  They concluded that the concept of ‘substantially lessening competition’ was well established in Australia and elsewhere

Creeping acquisitions

In relation to this issue the Committee (Xenophon dissenting) noted that the change proposed would be ‘arbitrary and contentious’.  Although they rejected the claim by opponents of the bill that the bill would set an absolute market share cap (although I’m not sure that in this respect they correctly interpreted the criticisms) they did find that the change could potentially harm the small business it was intended to protect.  They were also influenced by the Government’s current proposal to clarify the definition of market in relation to mergers, to ensure it was capable of including ‘local market’, which they considered might address some of the concerns raised about creeping acquisitions.

The dissent

Naturally Senator Xenophon, who introduced the bill, dissented and recommended passage of the bill with some modification.  He placed a lot of emphasis on the ‘Fares’ case (which doesn’t relate to merger law) and Zumbo’s 97% figure, rejected by everyone else as false evidence of the ‘leniency’ of Australia’s merger laws – claiming the statistic suggested the threshold was ‘far too onerous and high’.  He also claimed

The material lessening of competition test would assess the reduction in consumer choice as a result of a merger or acquisition, whereas the substantial lessening of competition test effectively only focuses on pricing power. [at 1.25]

This is patently false and, one would wonder where he got this idea, until you skip to paragraph 1.26 and see that it is derived from a quote from Assoc Prof Zumbo’s submission.  That, of course, does not make the statement true.

In relation to the creeping acquisition provision, the core focus of Senator Xenophon is protection of small business from ‘aggressive and arguably anti-competitive strategies of larger and more powerful corporations such as Woolworths’.  If that’s Xenophon’s concern, he’s focusing on the wrong provision – the proposed changes to the merger laws would not correct this and existing misuse of market power provisions already address this, at least to a degree – if he’s concerned with the way in which market power is used he should focus attention on s 46 and stop messing with our merger laws which represent international best practice.  He should also be reminded that protection of small business is not the goal of our competition law.


As a private member bill this one was always going to struggle to get up – but stranger things have happened in Australian competition law in the past – particularly in election years – so a general ‘phew’ describes my relief that the Senate Committee got it right this time – hopefully the Senate listens to them and buries the bill – hopefully deep enough that it doesn’t resurface any time soon.

View full report

Posted in Competition Policy, Legislation, Mergers | Tagged: , , | 1 Comment »

Creeping acquisitions … they won’t go away

Posted by Julie Clarke on 9 March 2010

The Government recently announced it would remove the reference to ‘substantial’ from the definition of markets for purposes of mergers (see previous post on this).  In so doing Craig Emerson claimed that the change would fulfill the Government’s election promise to deal with creeping acquisitions.  This, it was hoped, would end the crazy talk about substantial revisions to the merger laws and might result in the Government’s Discussion Paper 1 and Discussion Paper 2 on creeping acquisitions being swept under the carpet.

Not, however, if Assoc Prof Frank Zumbo has his way.  I have previously noted Zumbo’s claims, reported in the Fin Review, that the ‘anti-merger’ law (as he calls it) has ‘dangerous gaps and needs a major overhaul.’  Those ‘gaps’ weren’t explained in the Fin Review piece, but Zumbo has just published an article in the Trade Practices Law Journal (Zumbo, Don’t bank on bank competition: The case for effective laws against anti-competitive mergers and creeping acquisitions’ (2010) 18 TPLJ 26) in which he sets out his concerns about Australia’s current merger law and makes some radical (but familiar if you have read the earlier discussion papers and proposed  Richmond Amendment) recommendations for reform.  I won’t address them all but will note a couple of the highlights:

Substantial lessening of competition test to be replaced with ‘material lessening of competition’

This recommendation is, of course, identical to that proposed in the Richmond Amendment and with essentially the same (brief) reasons given – the current test, it is argued, imposes an almost insurmountable threshold for the ACCC.  No mention, of course, that the SLC test is what is adopted in most other countries and is consistent with other provisions in the Act, with the result that it provides greater certainty for business and their advisors.  This is particularly important for mergers, given that there has only been one case before the courts dealing with the current substantive merger test – as merger determinations are almost (in practice if not in law) the exclusive domain of the regulator, parties and their advisors need to look to judicial interpretation of this phrase in other parts of the Act.  ‘Material lessening of competition’ has no counterpart in the Act.   It is also not clear, as Zumbo claims, that ‘material lessening of competition’ would provide a ‘lower threshold’ for assessing mergers.

The catalyst for the change, according to Zumbo, is the high clearance rate of mergers in Australia (he claims the ACCC approves around 97% of mergers – this is a point made at least four times in this brief article) and that, according to him, ‘substantial lessening of competition’ has come to be equated with the ‘substantial market power’ test in s 46.  Nowhere is evidence provided for this and nowhere does he place this in context – this statistic is consistent with that produced by other merger regulators, including the US, and reflects the simple fact that most mergers are not anti-competitive.  He also claims this high clearance rate is responsible for the high concentration rate of markets in Australia, without any reference made to other possible contributors, such as Australia’s small population and relative geographic isolation.

The Senate Economics Committee was due to report on the Richmond Amendment next week, but has had its deadline extended until 18 May.

Targeting creeping acquisitions

Zumbo also claims, again relying on the high clearance rate of mergers as ‘evidence’ that our merger laws are ‘far too permissive’, that targeting creeping acquisition laws is ‘essential to having a world’s best competition law framework’ (without providing any evidence of how worlds best practice requires this – there’s no mention of it in International Competition Network or OECD merger recommendations and it is not an obvious feature of most merger laws around the world.  To address this concern, Zumbo recommends that corporations with substantial market share not be permitted to acquire shares or assets if it would lessen competition in a market. Essentially, if you have substantial market share (even if you have no power because of excess industry capacity, low barriers to entry or the threat of import competition) then you can’t merge because an ‘any lessening of competition’ threshold will almost always be met – at least for horizontal mergers.  Despite Zumbo’s concern about Australia having a ‘worlds best practice competition law’, no mention is made of the fact that merger decisions made on the basis of market share are expressly inconsistent with international best practice which recognises that market share provides a poor proxy for market power (and it is market power, not market share alone, which poses a threat to consumers).  In particular, the ICN Recommended Practices for Merger Analysis (developed in 2008 and revised in 2009) state clearly (Recommendation II(C)) that:

Jurisdictions that use market concentration and/or market shares to presume competitive harm should ensure that any such presumption may be overcome or confirmed by a detailed review of market conditions

Zumbo’s eagerness to substitute market share for market power contributed to the infamous Birdsville Amendment (see earlier post on this) to our misuse of ‘market power’ provisions.  Let’s hope the Government thinks better of making such a drastic change on this occasion.

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Creeping Acquisition Amendments Revisited

Posted by Julie Clarke on 4 February 2010

I have previously discussed the Government’s proposed changes to the definition of market, for purposes of mergers – essentially their plan to remove the word ‘substantial’, so that a merger would be prohibited where it substantially lessened competition in any local, regional or national market, whether or not that was considered a ‘substantial’ market.

The problem with the reform (or at least it’s effectiveness in achieving the government’s objective of curbing ‘creeping acquisitions’) is that the word ‘substantial” rarely, if ever, has any impact on the ACCC’s determination of the ‘relevant’ market for assessing likely competitive impact.  I’ve previously referred to comments by former chair of the ACCC’s Merger Review Committee, Prof Stephen King has made this observation in this respect:

Markets are based on substitution. If properly defined, an economic market for merger analysis captures the relevant level of competition. A market might be nationwide or even international. Or it may simply cover a single town or even part of a town … The key issues are – what is the nature of competition and what will the merger or acquisition do to this competition. If the merger substantially lessens competition in a properly defined economic market then it will harm consumers and the economy. The merger should be opposed. Requiring that the market is also ’substantial’ is redundant. So if Durie’s speculation is correct, the government will be getting rid of a redundant but confusing adjective!

The ACCC’s Merger Guidelines (updated in November 2008) also express the view that a ‘small’ market can be a ‘substantial market’ and that ‘substantial’ is not necessarily determined by geographic size. Although the Guidelines have no force in law, so a Court might interpret the meaning of ‘substantial’ differently in this context, the fate of mergers in Australia is, in practice, determined by the ACCC (there has been only one challenge to the ACCC’s decision not to informally approve a merger since the current test came into operation), so that its Guidelines reflect the current application of the law.  Consequently, although removal of the word ‘substantial’ may remove a ‘redundant’ term, it is unlikely to impact on the number or type of mergers approved by the ACCC.  It is clearly unlikely to have any impact on the ‘creeping acquisitions’ about which the Government seems so concerned.

This appears to be the consensus of opinion, as reported by Sam McKeith on page 11 of today’s Fin Review.  However, also reported in that item are commends by Assoc Prof Frank Zumbo and Queensland Consumers Association spokesman Ian Jarrett, that need to be challenged.  Zumbo claims that the ‘anti-merger law [first, it’s not an ‘anti-merger’ law, but I’ll let that one go] has dangerous gaps and needs a major overhaul.  This fiddling will not fill the dangerous gaps in the existing anti-merger law’.  It appears he also considers creeping acquisitions to be a ‘rapidly growing threat to competition and consumers’.  None of these claims appear justified.  It’s not clear what the ‘dangerous gaps’ are.  Our merger laws are broadly consistent with those in other OECD countries, which do not specifically or separately address ‘creeping acquisitions’, so that although in theory there is a gap in the law not addressing potentially anti-competitive impact of a series of small mergers, there is little evidence that this is currently a problem in practice (even the ACCC in its Grocery Report could not identify a problem associated with creeping acquisition in the grocery sector, despite having every incentive to do so: ‘The ACCC does not consider that acquisitions by Coles and Woolworths of smaller competitors over time are a significant current concern in the grocery retail sector’ (p xxi).  It’s also not clear what ‘major overhaul’ would be required to correct any perceived gap.

Ian Jarrett made a different but related claim, that ‘the high proportion of unopposed mergers indicated the ACCC needed more power to stop creeping acquisitions’.  This conclusion simply does not follow.  Most mergers are cleared because most mergers are not anti-competitive and the same holds true in most jurisdictions in which notification of mergers meeting certain thresholds is required; for example, the US challenges less than 5% of mergers notified to its competition agencies.

A law removing the word ‘substantial’ from the definition of market is to be welcomed because it is a redundant term which (it is clear) is capable of causing confusion.  But let’s not pretend it’s something that it is not and let’s not overstate the problem (if there is one) of ‘creeping acquisitions’ in this county.

Posted in Competition Policy, Mergers | Tagged: , , | 2 Comments »

No need for ‘substantial’ markets for mergers?

Posted by Julie Clarke on 22 January 2010

Out of the blue, the Government today announced it proposed to change the definition of market for purposes of merger review. The current definition of market refers to a ‘substantial market for goods or services’ and the proposal involves removal of the word ‘substantial’.

In his press release, competition minister Craig Emerson claims that this change is intended to fulfill the Government’s election promise to deal with ‘creeping acquisitions’.  It is tough to see how it will do this.  Former chair of the ACCC’s Merger Review Committee, Prof Stephen King has made this observation in relation to the proposed change:

Markets are based on substitution. If properly defined, an economic market for merger analysis captures the relevant level of competition. A market might be nationwide or even international. Or it may simply cover a single town or even part of a town … The key issues are – what is the nature of competition and what will the merger or acquisition do to this competition. If the merger substantially lessens competition in a properly defined economic market then it will harm consumers and the economy. The merger should be opposed. Requiring that the market is also ‘substantial’ is redundant. So if Durie’s speculation is correct, the government will be getting rid of a redundant but confusing adjective!

It is also unclear how this proposal fits with other proposals directed toward creeping acquisitions, including the Government’s own Creeping Acquisition Discussion Paper No 2 (for which submissions closed on 10 July 2009 and the proposed ‘Richmond Amendment‘, currently under review in the Senate.  The press release is light on detail in this respect.

The Conduct Code Agreement 1995 now requires the Government to consult with state and territory governments in relation to the proposed amendments (full details of which are not yet available) before their implementation.  Hopefully more details will emerge in the coming weeks.

The papers

News of the proposal was reported in the following papers this morning:

  • David Crowe, ‘ACCC gets tough on creeping giants’ Australian Fin Review, p 5.
  • John Durie, ‘Competition Minister takes aim at creep for control’, The Australian
  • John Durie, ‘Craig Emerson plans changes to the law to stop creeping takeovers’, The Australian
    Some notes on this item: it claims that ‘markets such as the US and the EC rely more on turnover tests than market share in determining whether a deal should be stopped.’ Actually, no they don’t.  The US and EU (we’re not allowed to call it the European Community anymore, post Lisbon Treaty) rely on turnover tests to determine whether parties MUST notify their mergers to relevant authorities; they impose a mandatory pre-merger notification obligation on mergers meeting certain threshold and jurisdictional tests.  Turnover itself is not part of the competition assessment in any of those jurisdictions.  In addition, the change to notification thresholds in the US from approx $65m to $63m (referred to in the article as evidence of the US ‘widening its net’) reflects an annual adjustment designed to account for changing levels of gross national product – it is designed to keep the ‘net’ steady, rather than to increase or reduce it.

Posted in Competition Policy, Legislation, Mergers | Tagged: , , , | 2 Comments »

Creeping acquisitions … the journey continues …

Posted by Julie Clarke on 1 December 2009

Yesterday the  Senate referred the Trade Practices Amendment (Material Lessening of Competition—Richmond Amendment) Bill 2009 (introduced into the Senate last Thursday) to the Senate Economics Committee for an inquiry and report.  This is a private member’s bill, rather than a Government bill, sponsored by Nick Xenophon.

The Bill proposes to amend the TPA in relation to creeping acquisitions.  The proposal involves ‘preventing corporations from directly or indirectly merging, or acquiring an asset, which would result in ‘material’ lessening of competition in the relevant market.  The word ‘material’ refers to a pronounced or  noticeably adverse effect on competition’, a lower threshold than the current test.   It would also prevent any corporation with substantial market share acquiring shares or assets if the acquisition would have the effect or likely effect of lessening competition (no material effect necessary).

This differs significantly from the two government issues papers on creeping acquisitions released last year and earlier this year.

I have much to say on the proposal but, as the Senate has requested withholding submissions until released by the Committee, I will refrain from expressing my views until a later date.  [Note: my submission has now been released by the Committee and can be viewed online] At this stage it is hard to know if this is a serious proposal (leaving aside content, as a private member’s bill it is almost certainly doomed to failure) or is designed to provoke the Government into releasing its own creeping acquisition legislation – something it originally promised to do by mid-this year.

One thing is certain: Economists will have fun with this one. So will I. Submissions are due by 18 December.  Reporting date is 18 March 2010.

View all submissions.

Posted in Legislation, Legislation (TPA/CCA), Mergers | Tagged: , | 3 Comments »

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