Civil partnerships

The cheese eating, surrender monkeys say "non".
 

Yet, it is reported that the French refuse to recognise the English civil partnership for French legal purposes, with the suggestion being that a same sex English couple wanting recognition of their legal standing for French purposes should annul their civil partnership and "re-marry" under French law. Being predictably bolshie, the French apparently have no problem with the Dutch, and are happy to recognise a Dutch civil partnership at French law. But, yet, our version is not good enough.

Whilst the French practice is, prima facie, discriminatory and contrary to France's international treaty obligations, it does serve to highlight that individuals with a cross border flavour to their circumstances need to be alert to the intricacies of dabbling in another country's legal system.

Despite it now being a good decade, if not longer now, since the upsurge in Brits acquiring holiday homes in Provence etc., there are still way too many people purchasing French property without first getting advice over the consequences, from both a UK and French tax perspective. With France having inheritance taxes as high as 60%, for example, the advance planning of one's affairs can prove particularly valuable in terms of avoiding unpleasant surprises.

In the UK, the Civil Partnerships Act 2004 enables same sex couples to register their relationship and be treated as if "married" for the purpose of English law. Section 215 of the Act gives recognition to same sex couples who have entered into an equivalent legal relationship in a jurisdiction outside of the UK. An example would be the pacte civil de solidarite, the French version of a same sex marriage.