European Parliamentarians are urging EU-wide recognition of same-sex partnerships or marriages created in member states.
At present some EU nations, such as Spain and Belgium allow gay marriages.
The UK has same-sex partnerships, a system that will be introduced in the Republic of Ireland.
Other nations such as France have registration systems that give gay and lesbian couples some rights.
The French pacte civil de solidarité (PACS) is fully recognised in Britain, but France does not recognise UK partnerships.
There is also hostility to any form of legal recognition in some new EU nations such as Poland.
Now the issue of cross-border recognition is to be raised in the European Parliament.
A declaration has been tabled on the issue. If it is signed by more than 50% of MEPs it will be adopted as a resolution.
It calls for “Member States with existing same-sex partnership legislation to recognise the arrangements of other Member States that have also made provisions for same-sex partnerships,” and for “guidelines for such mutual recognition by Member States with existing same-sex partnership legislation.”
Resolutions are formally adopted by the European Parliament and forwarded to the Commission, Council and Member State governments for consideration.
The declaration was tabled by Lim Dem MEP Sharon Bowles. Today her colleague Sarah Ludford, the party’s European justice & human rights spokeswoman backed the initiative.
“Legislative changes which have enabled legal partnerships for same-sex couples have greatly improved the quality of life of many in the LGBT community,” she said.
“But free movement rights which are supposed to belong to all EU citizens remain a fiction for gay couples if they are regarded just as two single people abroad.
“The current system whereby EU states ‘pick and choose’ when to grant recognition is causing inexcusable havoc for gay couples trying to exercise their right to move.
“The European Commission must act swiftly to end this anomaly of second-class status, and drag the member states into the modern world by proposing legislation for mutual recognition of same-sex partnership legislation.”
However, marriage is a family law issue that falls outside the competence of the Commission.
Any EU-wide agreement on the issue of same-sex recognition would require a consensus among member states.
GIven that politicians in Latvia, Poland and Lithuania are openly homophobic, such an agreement seems unlikely.
Last month PinkNews.co.uk spoke to Fernando Soares, a resident in France, who discovered that his UK civil partnership with his late partner was not recognised in that country.
This meant that Mr Soares would have to pay 60% inheritance tax on their property, unlike a heterosexual married couple or civil partners in the UK, and so was forced to sell their home.
Oliver Hepworth and his partner had a partnership ceremony in 2005. The couple bought a property in France ten years ago, but have since discovered that their relationship is not fully recognised in France.
Mr Hepworth told PinkNews.co.uk:
“Our British CP is not recognised in France at all and we have no legal rights as a couple over in France.
“We thought the solution would be to have a PACS over here but we were refused from doing this because we were already in a CP in the U.K.
“The registrar in France required the British embassy to issue a certificate de coutume to say that we are not in a legal civil partnership in the UK. Obviously we are.
“It seems that the tribunal recognises our civil partnership but not the French tax authorities or the French legal system.
“It seems really discriminating to British nationals since the French have a same sex partnership called the PACS, and they also give gay Dutch married couples full legal recognition.
“Alas British gay couples are discriminated against.”
There has also been confusion over whether or not Spain recognises civil partnerships formed in the UK.