Gli effetti nell’ordinamento italiano delle unioni civili e dei matrimoni same-sex conclusi all’estero

Legislative Decree no. 7 of 19th January 2017 has reformed Italian private international law by including same-sex civil partnerships and marriages within its scope of application. And yet, domestic and European case law show that the recognition of same-sex partnerships and marriages concluded abroad remains a sensitive subject matter. Indeed, while the reform has solved some interpretative problems, others remain or are even exacerbated, and new ones have arisen. This paper attempts to take stock of the Italian regime and practice, and highlights what Italy shall or should recognise in the light of its obligations stemming from European Union law and from the European Convention on Human Rights.