Britain
There is no recognition in English law for same-sex couples. They cannot marry and must pay inheritance tax if their partner leaves any of his or her estate to them. They cannot benefit from the married couple's tax allowance. If one member of a same-sex couple dies without leaving a will, the surviving partner can be legally thrown out of their home by the late partner's family. The only concession to gay couples in Britain concerns immigration: same-sex partners can now live in Britain if they have cohabited for four or more years.

Denmark
The country passed a law on May 21st 1999 allowing homosexuals in a state-registered partnership to adopt their partner's children. Ten years ago, Denmark became the first country to set up a system for formalising partnerships in same-sex couples, allowing them all the legal rights of heterosexual couples except adoption or conception through artificial insemination. Adoption outside a formalised relationship is still forbidden.

United States
Only one state, Hawaii, gives legal recognition to same-sex couples, allowing them the same inheritance, tax, property and medical rights as heterosexual couples. In 1993, the Hawaiian Supreme Court also ruled that three same-sex couples should be permitted to marry. This ruling went to appeal and a final decision is awaited. If a lawsuit currently going through the courts in Vermont is decided in favour of legalising same-sex marriages, this could open the doors for other states to recognise such unions.

Australia
This month the New South Wales government decided to honour its four-year-old election promise to give same-sex couples the same legal rights as heterosexual couples. New South Wales is the only state to do this. Gay and lesbian groups are currently lobbying hard for a right to marriage.

France
Earlier this year the Pacs law was passed, paving the way for couples living in a stable relationship - unmarried heterosexuals and same-sex couples - to demand the same civil rights as married couples if they register at their town hall. The legislation covers tax statutes, right to property and transfer of money. Same-sex couples cannot get married in a church or adopt children.

(Nicola Branch, the Guardian, May 22nd 1999)