DISHARMONY IN ACCOUNTING ASPECTS OF CROSS-BORDER MERGERS IN EUROPE COMING FROM THE IMPLEMENTATION OF THE 10TH DIRECTIVE

This paper examines regulation of cross-border mergers in Europe executed by implementation of the 10th EC directive into national law in European countries. We provide evidence that preparatory phase of cross-border merger is subject to the national laws of the Member State where cross-border merger is realized. We illustrate that even the first step in the preparatory phase - determination of decisive day - in some European countries could differ. Using the example of the Czech Republic, we came to the conclusion that under the present conditions, cross-border merge between companies of some countries are not allowed legally to be realized. This findings calls for re-examination of the 10th EC Directive or accounting legal systems of European countries and thus contribute to further cross-border merges.