The elastic interaction energy between tetragonal zirconia precipitates for different mutual orientations is considered. The results of numerical analysis of this procedure are compared with experimentally observed preferred orientation relationships in the ceria-magnesia-partially stabilized zirconia (CM-PSZ) system. Two variants appear favourable, a parallel-stepped precipitate configuration with precipitate centres stepped at about 20 degrees, and orthogonal precipitates in an edge-face configuration.