This article offers a comparative analysis of the property consequences of non-marital relationships in New Zealand and Scotland. The article summarises and critiques the New Zealand system, where de factos are dealt with alongside married couples through the Property (Relationships) Act 1976, before analysing the provisions of the Family Law (Scotland) Act 2006 which establish a scheme for regulation of non-marital couples entirely separate from existing divorce law. An alternative regime, based on assessment of a percentage entitlement to the claim a spouse would have received in equivalent circumstances, is then proposed as a solution to the difficulties in both jurisdictions
