Board of Directors and Shareholder Relationship: A comparative approach between the UK and Italy

Before the UK's departure from the European Union (EU), EU law played a significant role in the English legal framework. Brexit, which officially took place on January 31, 2020, led to changes in various legal, regulatory, and economic aspects that could affect corporate governance practices.

For a chronological ground base, the UK entered into a trading relationship with the EU under the EU-UK Trade and Cooperation Agreement (TCA) for an 11-month transition period which ended on 31 December 2020, a date which was nicknamed 'IP Completion Day'. Under this transitional period, the UK was still subject to the EU rules (Simmons and Simmons, 2021).

First, with the UK no longer being bound by EU laws and regulations, it gained the opportunity to develop its own corporate governance framework independently. Although the UK Companies Act 2006 is influenced by European legislation, there are no current proposals in terms of amendments or significant reviews.

Alongside the newly introduced requirement for additional information for those EEA Companies registered under the UK establishment, we can find some of the following modifications following Brexit:
• No freedom of establishment, as a consequence UK companies willing to establish in EU Member States will need to comply with the member state's national regulation. Since the IP Completion Day, UK companies have been known as "third country companies" for EU law purposes.
• UK companies with an EEA listing will produce accounts in accordance with the UK Companies Act 2006 but they have to comply with the local jurisdiction of the member state where they are located; this may include the publication of accounts using the 'EU-adopted IAS'.
• Societas Europaea (SE) can no longer be registered in the UK. If not taken care of, they will become "UK Societas" and consequently be converted into a new UK corporate structure.
• UK-incorporated companies will have to use the 'UK-adopted IAS' for the financial years beginning after 31 December 2020.

All the Companies involved after Brexit, had three months since the IP Completion Day to make the due changes. Brexit has affected cross-border trade and investment between the UK and the EU. This impact could influence corporate governance practices, as companies navigate changes in supply chains, legal structures, and investor relations.

However, the Brexit impact also led to changes in immigration rules and the ability of EU citizens to work in the UK which in the long run have implications for board composition and workforce diversity. Thus, Companies might need to adjust their recruitment strategies and talent management practices accordingly.