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LOI and SPA in International Deals: Key Aspects When Combining CEE Companies

M&A Radar·2 min read·Updated 2026

From a handshake to a signed deal, two documents lead the way: the LOI and the SPA. Understanding what each sets out and where the risks lie is essential for any cross-border CEE deal.

1. LOI: the letter of intent

The LOI (Letter of Intent) sets out the deal's core terms before detailed due diligence: price (or price formula), structure, exclusivity and timeline. Most of an LOI is not legally binding (except confidentiality and exclusivity) but sets the tone and direction.

2. Between LOI and SPA: due diligence

The LOI is followed by due diligence. Findings may adjust price or terms. This is exactly where a prepared data room and clean financials decide whether the deal moves smoothly or stalls.

3. SPA: the share purchase agreement

The SPA (Share Purchase Agreement) is the final, binding contract. Core elements: price and price adjustments, representations and warranties, indemnities, and conditions before and after closing.

4. Cross-border nuances

Several jurisdictions mean different law, tax and enforcement. The dispute-resolution clause (e.g. arbitration) and governing law are not a formality but essential protection. Local legal advice is essential.

FAQ

What's the difference between an LOI and an SPA?

The LOI sets out core terms before due diligence and is mostly non-binding (except confidentiality/exclusivity); the SPA is the final, legally binding purchase agreement.

What matters most in an SPA?

Price and price adjustments, representations and warranties, indemnities, and conditions before and after closing.

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