Maire Ní Shúilleabháin (University College Dublin School of Law) has recently posted to SSRN her paper, Same-Sex Couples in European Private International Law: Finding a Path Through the Labyrinth. Here is the abstract:
Globally – and within Europe – domestic laws on formalization of adult relationships are extremely diverse and in transition. Same-sex couples now enjoy a right of marriage in fourteen EU Member States, and in twenty other countries worldwide (including five European countries which are not in the EU). In some other countries, including several European states, both EU and non-EU, registered partnership is offered as the sole means of formalization of same-sex relationships (an offering which is often a step towards marriage equality). In the many remaining countries across the world (including a substantial number of European states) there is, at present, no facility under domestic law for formalization of same-sex relationships (although in some of these countries change may be imminent).