Theresa May is to push ahead with a new system to vet foreign investment in Britain, but has heeded warnings from chancellor Philip Hammond that the country cannot afford to adopt "French-style" protectionism.

The UK prime minister wants the government to be able to intervene in an "orderly and structured" way in sensitive foreign investments and is studying regimes used in other countries, such as the US and Australia.

But last month Mr Hammond led a chorus of warnings that any new regime must not undermine Britain's position as Europe's top destination for foreign direct investment, particularly with Brexit approaching in 2019.

"We can't go down the Danone route," Mr Hammond said, referring to action taken by the French government a decade ago that appeared to be intended to prevent a takeover of the yoghurt maker Danone.

Mrs May is insisting Britain should have a more transparent regime covering specified foreign investment, allowing ministers to intervene "to get the best deal for the UK". The issue is at the heart of the dilemma facing Mrs May, who believes that June's Brexit vote was partly a rejection of globalisation but who also recognises that Britain needs to be an open and free-trading nation after it leaves the EU.

Mrs May's allies say she dislikes the informality that saw her predecessor David Cameron give the green light to Pfizer's bid for AstraZeneca, only for the deal to collapse.

Many other countries have adopted a foreign investment regime, such as France, Australia and the US. In particular, Mrs May is looking at whether scrutiny of the deal through a framework such as Canberra's Foreign Investment Review Board or the Committee on Foreign Investment in the US could allow ministers to intervene to seek guarantees on issues such as jobs and taxes.

"A proper industrial strategy wouldn't automatically stop the sale of British firms to foreign ones but it should be capable of stepping in to defend a sector as important as pharmaceuticals is to Britain," Mrs May said in July, before becoming prime minister.

"At the moment our regime is sometimes unclear, leaving investors without certainty and the government with few options to scrutinise in order to get the best deal for the UK," said a spokeswoman for Mrs May.