In recent years there have been a number of significant procedural developments that have affected merger review of life sciences transactions. At EU level, the European Commission (EC) has sought to ensure that it has the ability to review ‘killer acquisitions’ that do not meet the EC Merger Regulation (EUMR) turnover-based thresholds, using the power of Member States to refer transactions. In March 2021, the EC published new guidance regarding these Article 22 referrals, setting out…