On the 1st of January 2021, an amendment to the Business
Corporations Act (Act No. 33/2020 Coll.) came into force, which brought fundamental
changes in corporate law. This article presents the practical implications of
one of them, concerning the condition of approval of the transfer or pledge of
the plant and part of the assets by the general meeting of the company
(Sections 190(2)(i) and 421(2)(m) of the Corporations Act). In which cases and
whose approval is needed?
Once upon a time
Prior to the 1st of January 2021, the relevant provisions
concerning the condition of the General Meeting's approval of the transfer or
pledge of the plant read as follows: 'The General Meeting shall have the power
to approve the transfer or pledge of the plant or any part thereof which would
entail a material change in the existing structure of the plant or a material
change in the company's business or activities'.
The term "part of the race" posed an
interpretative problem. Whether it should be understood as a "formal"
concept, where a part of the plant would be interpreted as a separate
organizational unit (branch) within the meaning of Section 503 of the Civil
Code, or as a "material" concept, where a part of the plant means any
property component of the plant, the transfer of which would entail a material
change in the existing structure of the plant or a material change in the
object of the company's business or activity. The parties to the transactions
were thus in uncertainty as to whether the specific transfer agreement was
subject to the approval of the general meeting.
The Supreme Court solved this problem of interpretation in
its decision 27 Cdo 2645/2018, dated 29 May 2019, which leaned towards the
so-called formal-material interpretation. This means that at the same time the
formal prerequisite must be met, i.e. it must be a separate organizational unit
that also meets the material features, i.e. its transfer would mean a
substantial change in the existing structure of the plant or a substantial
change in the subject of the company's business or activity.
However, this short period of legal certainty came to an end
when the amendment came into force.
Here we go again
After the amendment, the consent of the general meeting is
subject to the transfer or pledge of the plant or such part of the assets that
would constitute a material change in the actual object of the company's
business or activity.
The term "part of the plant" has thus been
replaced by "part of the assets", thus definitively abandoning the
formal interpretation. After the amendment, a part of the assets will be
interpreted only materially, i.e. it will be assessed only whether a given
transaction may constitute a material change in the actual (not formal) object
of the company's business or activity. However, this will be very difficult to
assess in some cases.
Another surprise
The amendment has prepared another unpleasant surprise for
us. According to the original legislation, there was a consensus that the
condition of the general meeting's consent to the transfer or pledge of the
plant or part of it applied only to the transferor's (alienator's) company, not
to the acquirer's company. However, this also seems to be changing. The
Explanatory Memorandum to the amendment states that the transfer is understood
to be both a sale and a purchase, and thus the consent of the general meeting
will also (or only) have to be obtained from the purchaser in qualified cases.
This entails additional costs and increases legal uncertainty.
Similarly, the new regulation also applies to pledgees (in
cases of forfeited pledge or negotiations of a security transfer). Even a
pledge of a plant may result in a substantial change in the actual business or
activity of the pledgee. In such cases, it will therefore be necessary to
obtain the consent of the general meeting of the pledgee for the pledge.
What to do if consent has not been given
In cases where the transaction is not approved by the
general meeting in violation of the law, such contracts will suffer from a
defect for which the beneficiaries (the company and the shareholders) may bring
an action before the court within the statutory time limit for its nullity.
Thus, in practice, even in disputed cases, the approval of the general meeting
will be required, which will increase the cost of the entire transaction.
If you have already entered into such an agreement after 1
January 2021 without the approval of the general meeting, this can be remedied.
Consent can also be granted retrospectively, which will cure the defect in the
contract. Provided, of course, that one of the beneficiaries has not already
objected to its lack of validity in court and both parties agree to such a
procedure.
Author: Aneta Koubková
The Article has been published on © EPRAVO.CZ.