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RESEARCH PRODUCT

Le partenariat enregistré en droit international privé

Marc Mignot

subject

General Arts and Humanities

description

Numerous European countries enable couples of both the saine and different sexes to enter a registered partnership. In the South, a partnership is available to couples of both the same and different sexes and sets up a new form of personal union. In the North, a partnership is available to persons of the same sex and has practically the same consequences as marriage. The law applicable to partnership depends on its specifie nature. In one case, French law concerning registered partnership clashes with an equivalent foreign law. In the other, French law concerning marriage clashes with foreign law concerning same-sex marriage.

10.3406/ridc.2001.17945https://www.persee.fr/doc/ridc_0035-3337_2001_num_53_3_17945