The concept of a registered civil partnership provides certain rights to same-sex couples or heterosexual couples who opt for this path. But what happens if you add a cross border component to it? What impact does this have? Do you know what your rights will be if you move to another country?
In this guide we will focus on comparing two very different legal systems, the UK and Spain.
To begin with, we would like to bring up two ideas to the fore. The first, there is no legal equivalent under Spanish law to the concept of civil partners as understood under English law.
And the second, which is directly related to the first, the rights you get in England as a civil partner will not be the same as they are in Spain or any other country.
The Civil Partnership Act 2004 (the Act) made specific provision for recognition in the United Kingdom of civil partnerships entered abroad according to the law of that country. In Schedule 20 of the Act there is a list of countries which have their own civil partnership law and whose civil partnerships will be recognised in England and vice versa. Therefore, an English civil partnership would be recognised as a civil partnership in those countries listed. However this doesn’t mean that all the rights and entitlements of an English civil partnership will apply in the other country.
Through this comparative guide, we have tried to summarise the most important sections of the regulation of registered partnerships, their characteristics, and rights, both in the United Kingdom and in Spain, to understand the main differences at a glance.
Click here to download the guide:
Marc White Civil Partnerships in UK and Spain Comparative Guide
This post was written by Pilar Cerruti: pilar@mwnotary.com
Graphic by Danny Jenkins and belongs exclusively to Marc White & Co and Danny Jenkins.
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