1. INTRODUCTION During the trial session of September 5, 2018, the Tribunal of the Brazilian Competition Authority (“CADE”) requested the submission of a transaction that did not trigger the mandatory notification thresholds. -  In short, the transaction concerns the acquisition of All Chemistry do Brasil (“All Chemistry”) by SM Empreendimentos Farmacêuticos (“SM Empreendimentos”).  Both companies operate in distribution sector of pharmaceutical supplies, focusing on chemist’s shop segment.  The Reporting-Commissioner based its decision on article 88, paragraph 7, of Law No. 12.529/2011 (the “Brazilian Competition Law”), which allows CADE to request submission of transactions that would not notifiable, within up to one year from its
The Brazilian Competition Authority requests the submission of a below-threshold transaction between two distributors of pharmaceutical supplies (All Chemistry / SM Empreendimentos)
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