Doing transatlantic M&A: Differences and best practices

After recent volatile years, dealmakers expected more transatlantic M&A deals in 2025. During the year, it became increasingly apparent that macroeconomic challenges and geopolitical uncertainty have continued to take their toll, as transatlantic deal volume was down more than 10% in the first half of 2025 (YoY). 

Navigating the complexities of connecting parties from both sides of the Atlantic remains a challenge. 

Understanding characteristics in Europe and USA: Key to conducting successful transatlantic M&A

Understanding the various differences between EU and US businesses, markets, and owners encompasses a range of dimensions. It is obligatory to acknowledge the different “ways of doing business” and tailor your approach to the culture of specific regions. A simple, recurring example is aligning quality expectation mindsets between “perfection” (Europe) vs “good enough” (US). Value chains and go-to-market channels often differ. 

Europe generally provides well-educated, blue-collar labour and lower labour costs for industrial manufacturing, with larger regional variance as well as more holiday and social benefits. Overall, Europe is a very heterogenous market, where every country differs in culture and structure.

In the US, businesses are often more M&A experienced and the risk appetite is higher. This is reflected in financing availability, willingness to deploy more capital, and more ambitious growth plans.

Purchase agreement standards differ in many commercially relevant clauses. That includes:

• Closing mechanisms: Purchase price adjustment (PPA) is standard in the US, while locked-box is the EU alternative; 
• Larger US market for warranty and indemnity (W&I) insurance;
• Material Adverse Change (MAC) clauses are standard only in US; 
• The everchanging field of tax & antitrust, where regulations are tightening and expertise in individual country legislation is required to navigate fragmented foreign direct investment (FDI) regimes, compared to the Committee on Foreign Investment in the United States (CFIUS) centralised approach to reviews. 

In-depth, transparent discussion on transatlantic M&A goals and pitfalls sets your client up for success.

One of the responsibilities of the M&A advisor is to educate the client on regional differences early. Additional preparation work usually prevents avoidable, unpleasant surprises later on.

Best practices include:

• Understand the playing field: Analyse market, value chain and technology, have a clear definition of target criteria, and conduct a “reality check”;
• Strategic sparring partner approach rather than execution-driven: Focus on relationship building and maintain this throughout the process by staying hands-on;
• Ask the right questions about financials, technology, sales, competition, employees, and management;
• Adhere to local M&A habits through “boots on the ground” support and local counsel.

The 2026 outlook is optimistic – similarities between the EU and US outweigh the cultural differences and geopolitics that drive transatlantic M&A considerations. Advisors will benefit most when they are able to communicate peculiarities and tailor their approach accordingly, thereby adding strategic value for their client. 

---

Fabius Janssen is a vice president at Delphi Advisors, with considerable experience advising on pan-European and transatlantic M&A transactions. His industrial and industrial tech sector expertise includes flow control (e.g. pumps, valves, seals), automation & robotics, and manufacturing and logistics.