Abstract
The article analyzes the legal hurdles that same-sex couples face when seeking recognition of their same-sex marriages abroad, using the case of Vietnam as an example. By logically assessing how the national legal framework responds to foreign same-sex marriages, the article highlights the need to be aware of the nature and proper application of the following private international law techniques: preserving public order, the possibility of claiming legal effects of same-sex marital relationships, and indirect recognition. The article also proposes harmonization of legal rules and innovative judicial solutions to unlock the global potential of the cross-border recognition of the legal effects and rights of same-sex couples, especially taking into account the experiences of a developing Asian country.
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