Multiple citizenship

Multiple citizenship, also called dual citizenship or multiple nationality or dual nationality, is a person's citizenship status, in which a person is concurrently regarded as a citizen of more than one state under the laws of those states. There is no international convention which determines the nationality or citizen status of a person, which is defined exclusively by national laws, which vary and can be inconsistent with each other. Multiple citizenship arises because different countries use different, and not necessarily mutually exclusive, criteria for citizenship. Colloquial speech refers to people "holding" multiple citizenship but technically each nation makes a claim that this person be considered its national.

Some countries do not permit dual citizenship. This may be by requiring an applicant for naturalisation to renounce all existing citizenship, or by withdrawing its citizenship from someone who voluntarily acquires another citizenship, or by other devices. Some countries do not permit a renunciation of citizenship. Some countries permit a general dual citizenship while others permit dual citizenship but only of a limited number of countries.

Most countries that permit dual citizenship still may not recognize the other citizenship of its nationals within its own territory, for example, in relation to entry into the country, national service, duty to vote, etc. Similarly, it may not permit consular access by another country for a person who is also its national. Some countries prohibit dual citizenship holders from serving in their military, on police forces or holding certain public offices.[1]


Up until the late 19th century, nations often decided who they claimed as their citizens or subjects, and did not recognize any other nationalities they held. Many states did not recognize the right of their citizens to renounce their citizenship without permission, with the feudal theory of perpetual allegiance to the sovereign still common. This meant that people could hold multiple citizenships, with none of their nations recognizing any other of their citizenships. This state of affairs sometimes led to international incidents, notably the War of 1812, triggered by British impressment of American seamen who were alleged to be British subjects into naval service.[2]

In the aftermath of the 1867 Fenian Rising, Irish-Americans who had gone to Ireland to participate in the uprising and were caught were charged with treason, as the British authorities considered them to be British subjects. This outraged many Irish-Americans, to which the British responded by pointing out that, just like British law, American law also recognized perpetual allegiance.[2] As a result, Congress passed the Expatriation Act of 1868, which granted Americans the right to freely renounce their U.S. citizenship. Britain followed suit with a similar law, and years later, signed a treaty agreeing to treat British subjects who had become U.S. citizens as no longer holding British nationality. During this time, diplomatic incidents had also arisen between the United States and several other European countries over their tendency to conscript naturalized American citizens visiting their former homelands. In response, the US government negotiated agreements with various European states known as the Bancroft Treaties, under which the signatories pledged to treat the voluntary naturalization of a former citizen or national with another sovereign nation as a renunciation of their citizenship.[2]

As a result, the theory of perpetual allegiance largely fell out of favor with governments during the late 19th century. With the consensus of the time being that dual citizenship would only lead to diplomatic problems, more governments began prohibiting it, and revoking the nationality of citizens holding another nationality. By the mid-20th century, dual nationality was largely prohibited worldwide, although there were exceptions. For example, a series of U.S. Supreme Court rulings permitted Americans born with citizenship in another country to keep it without losing their U.S. citizenship.[2][3]

At the 1930 League of Nations Codification Conference, an attempt was made to codify nationality rules into a universal worldwide treaty, the 1930 Hague Convention, whose chief aims would be to completely abolish both statelessness and dual citizenship. It proposed laws that would have reduced both, but in the end was ratified by only twenty nations.[2]

However, the consensus against dual nationality began to erode due to changes in social mores and attitudes. By the late 20th century it was becoming gradually accepted again.[2] Many states were lifting restrictions on dual citizenship. For example, the British Nationality Act 1948 removed restrictions on dual citizenship in the United Kingdom, the 1967 Afroyim v. Rusk ruling by the U.S. Supreme Court prohibited the U.S. government from involuntarily stripping citizenship from Americans over dual citizenship, and the Canadian Citizenship Act, 1976, removed restrictions on dual citizenship in Canada. The number of states allowing multiple citizenship further increased after a treaty in Europe requiring signatories to limit dual citizenship lapsed in the 1990s, and countries with high emigration rates began permitting it to maintain links with their respective diasporas.[4]

Citizenship of multiple countries

Main articles: Citizenship and Naturalization

The rights of citizenship are determined by each country, which sets its own criteria for citizenship. These laws may create situations where a person may satisfy the citizenship requirements of more than one country simultaneously. This would, in the absence of laws of one country or the other, allow the person to hold multiple citizenship. National laws may include criteria as to the circumstances, if any, in which a person may concurrently hold another citizenship. A country may withdraw its own citizenship if a person acquires a citizenship of another country, for example:

Once a country bestows citizenship, it may or may not consider a voluntary renunciation of that citizenship to be valid. In the case of naturalization, some countries require applicants for naturalization to renounce their former citizenship. For example, United States Chief Justice John Rutledge ruled "a man may, at the same time, enjoy the rights of citizenship under two governments",[12] but the United States requires applicants for naturalization to swear to an oath renouncing all prior "allegiance and fidelity" to any other nation or sovereignty as part of the naturalization ceremony.[13] However, some countries do not recognise one of its citizens renouncing its citizenship. Effectively, the person in question may still possess both citizenships, notwithstanding the technical fact that he or she may have explicitly renounced one of the country's citizenships before officials of the other. For example, the United Kingdom recognises a renunciation of citizenship only if it is done with competent UK authorities.[14] Consequently, British citizens naturalized in the United States remain British citizens in the eyes of the British government even after they renounce British allegiance to the satisfaction of United States authorities.[11]

Irish nationality law applies to "the island of Ireland", which extends citizenship to Northern Ireland, which is part of the United Kingdom. Therefore, anyone born in Northern Ireland who meets the requirements for being an Irish citizen through birth on the "island of Ireland" (or a child born outside Ireland but with a qualifying parent) can exercise rights accorded only to Irish citizens, including that of traveling under an Irish passport. Under Irish law, even if such a person has not acted in this way does not necessarily mean that they are not entitled to Irish citizenship. (See Irish nationality law and British nationality law.) People born in Northern Ireland are also British citizens on the same basis as people born elsewhere in the UK. People born in Northern Ireland may generally choose to hold a British passport, an Irish passport, or both.[11]

Multiple citizenship avoided

Some countries consider multiple citizenship undesirable and take measures to avoid it. Since a country has control only over who has its citizenship, but has no control over who has any other country's citizenship, the only way for a country to avoid multiple citizenship is to deny its citizenship to people in cases when they would have another citizenship. This may take the following forms:

Involuntary multiple citizenship

Involuntary multiple citizenship can happen in two ways:

  1. If the parents of a child have different citizenships or are multiple citizens themselves, the child may gain multiple citizenship depending on whether and how jus soli and jus sanguinis apply for each citizenship.
  2. Some countries (e.g., Canada, the United States of America and many other countries in the Americas) regard all children born there automatically as citizens even if the parents are not legally present (jus soli). For example, a child born in the United States to Norwegian parents automatically has dual citizenship with the United States and Norway, even though Norway usually restricts or forbids dual citizenship.
    This has led to birth tourism, so some countries have abolished jus soli or restricted it (i.e., at least one parent must be a citizen or a legal, permanent resident who has lived in the country for several years). Some countries forbid their citizens to renounce their citizenship or try to discourage them from doing so.[11]

Complex laws on dual citizenship

Some countries do not simply allow or forbid dual or multiple citizenship in general, but have more complex rules, such as:

EU and EFTA countries

The EU and EFTA countries have various policies regarding dual citizenship, because each country can make its own laws. The only real rule is that a citizen of an EU country can live and work indefinitely in other EU countries and in the four EFTA countries (and citizens of the EFTA countries can live and work indefinitely in the EU). However, the right to vote and work in certain sensitive fields (such as government, police, military) might in some cases be restricted to the local citizens only.

The countries can exclude immigrants from getting welfare in the first three months to avoid "welfare tourism", and they can refuse welfare completely if the immigrants do not have a job after a certain period of time and do not try to get one. Immigrants convicted of welfare fraud can be deported and be refused the re-entry of the country. On September 15, 2015, the European Court of Justice ruled that EU countries can refuse to pay unemployment benefits to immigrants who have lost their job even if they are citizens of other EU countries. The judge stated that EU rules allow member states to refuse unemployment benefits to people from other EU nations to stop them becoming "an unreasonable burden on the social assistance system of the host Member State". This backs up a November 2014 ruling, in which the court ruled that "poverty immigrants" who came to Germany just to receive social security benefits were not entitled to receive them.[33][34]

Within the EU, mandatory military service exists, at least in peacetime, only in Austria, Cyprus, Estonia, Finland, and Greece (In all countries but Cyprus, alternative service is available). Within the EFTA countries, only Switzerland requires it (alternative service is available); Iceland and Liechtenstein have no armed forces; in Norway, military service is de jure mandatory, but the enforcement is limited, so some sources claim it is de facto voluntary.

In Liechtenstein and in the Swiss Canton of Schaffhausen, voting is compulsory for citizens.

In the European Union, voting is mandatory for national citizens in:

The four microstates (Andorra, Monaco, San Marino, and Vatican City) are not EU or EFTA members. Between them, the EU, and the EFTA there is visa-free travel, but no agreements on immigration and access to the job markets.

EU countries

For details, see the nationality law of the country concerned and Citizenship of the European Union.[35]

Austria - (see above) dual citizenship is possible with special permission or if it was obtained at birth.
Belgium - allows dual citizenship.
Bulgaria - Bulgarian citizens of descent can have dual citizenship, but foreigners wanting to naturalize must renounce their old citizenship.
Croatia - generally allows citizens by descent to have dual citizenship and forbids it only in certain cases, but foreigners wanting to naturalize must renounce their old citizenship.
Cyprus - allows dual citizenship.
Northern Cyprus is not generally recognized by the international community as a sovereign state. No nation other than Turkey has officially recognised Northern Cyprus.[36] The United Nations considers the declaration of independence by Northern Cyprus as legally invalid, as enunciated in several of its resolutions.[37][38] The United Nations recognises Northern Cyprus as territory of the Republic of Cyprus under Turkish occupation.[37] Turkey permits Citizens of Northern Cyprus to live and work in Turkey under the same requirements as Turkish citizens, and provides a special type of passport for Northern Cyprus citizens.
Czech Republic - has allowed multiple citizenship since January 1, 2014.[39]
Denmark - allows dual citizenship since September 1, 2015. Note that not all Danish citizens are EU citizens (see below).
Estonia - forbids dual citizenship, but citizens by descent cannot be deprived of their Estonian citizenship, so they de facto can have dual citizenship.
Finland - allows dual citizenship.
France - allows dual citizenship.
Germany - (see above) allows dual citizenship with other EU countries and Switzerland; dual citizenship with other countries is possible with special permission or if obtained at birth; children of non-EU/non-Swiss legal permanent residents can have dual citizenship if born and grown up in Germany (the parents born and grown up abroad must have resided in Germany for at least eight years and must have had the legal-permanent-resident status for at least three years, and usually cannot have dual citizenship themselves).
Greece - allows dual citizenship.
Hungary - grants dual citizenship to people living in, and having ancestors in territories which were annexed from Hungary at the end of World War I, provided they can still speak Hungarian.
Ireland - allows and encourages dual citizenship, but a naturalized citizen can lose Irish citizenship again when naturalizing in another country; Ireland was the last European country to abolish unconditional birthright citizenship [in 2004] in order to stop "birth tourism" and to replace it by a modified form: at least one parent must be a citizen or a legal permanent resident.
Italy - allows dual citizenship.
Latvia - from October 1, 2013, dual citizenship with Latvia has been allowed for citizens of member countries of EU, NATO and EFTA [Iceland, Liechtenstein, Norway, Switzerland]; citizens of Australia, Venezuela, Brazil, New Zealand; citizens of the counties that have mutual recognition of dual citizenship with Latvia; people who were granted the dual citizenship by the Cabinet of Ministers of Latvia; people who have applied for dual citizenship before the previous Latvian Citizenship law [1995].
Lithuania - Article 12 of the Lithuanian Constitution states that only in "individual cases provided for by law" is dual citizenship permitted. [Constitution of the Republic of Lithuania, adopted on Oct. 25, 1992, in force from November 2, 1992].
Luxembourg - allows dual citizenship.
Malta - allows dual citizenship.
Netherlands - dual citizenship is allowed under certain conditions: e.g., foreign citizenship may be kept if obtained at birth or in the event of naturalization via marriage.
Poland - does not deal with the issue of dual citizenship, but possession of another citizenship is tolerated since there are no penalties for its possession alone. However, penalties do exist for exercising foreign citizenship, such as identifying oneself to Polish authorities using a foreign identification document or serving in a foreign military without permission of Polish military authorities. Dual citizens are not exempted from their duties as Polish citizens. Under some circumstances, ethnic Poles can apply for the "Polish Card" [Karta Polaka]. (see below)
Portugal - allows dual citizenship.
Romania - allows dual citizenship.
Slovakia - dual citizenship is permitted to Slovak citizens who acquire a second citizenship by birth or through marriage; and to foreign nationals who apply for Slovak citizenship and meet the requirements of the Citizenship Act. Please note that after the 'Hungarian-Slovak citizenship conflict' (year 2010) some restrictions to dual citizenship may apply.[40]
Slovenia - generally allows citizens by descent to have dual citizenship and forbids it only in certain cases, but foreigners wanting to naturalize must renounce their old citizenship.
Spain - (see above) Spanish citizens by descent can have dual citizenship; Spanish laws knows a "dormant citizenship" for citizens naturalizing in Iberoamerican countries: They do not lose their citizenship, but their status and their rights as citizens of Spain—and of the EU—are inactive until they move back to Spain. Foreigners wanting to naturalize in Spain must usually renounce their old citizenship; exceptions are made for citizens of some Iberoamerican countries, Puerto Rico, Andorra, the Philippines, Equatorial Guinea, and Portugal. Since 2014, Spain has granted Spanish nationality to Sephardi Jews regardless of nationality.[41]
Sweden - allows dual citizenship.
United Kingdom - allows dual citizenship. Note that not all British citizens are EU citizens (see below). On June 23, 2016, British citizens voted to leave the European Union. The effect on British Citizens' EU Citizenship is yet to be formally negotiated officially announced, but it is expected that British Citizens will lose EU Citizenship in the future.
The Channel Islands of Guernsey and Jersey and the Isle of Man are British Crown dependencies. Unlike the United Kingdom proper and Gibraltar (a British overseas territory in Europe), the Crown dependencies are not considered part of the EU for most purposes.
The Faroe Islands belong to Denmark, but not the EU, so their inhabitants are Danish citizens, but not EU citizens. Greenland left the EC in 1985, but Greenlanders are considered EU citizens.
These British and Danish citizens obtain or procure "local" passports. In practice, citizens of Faroe Islands and Greenland can choose between local and "European" passports, and citizens of Guernsey, Jersey, and the Isle of Man receive passports bearing the title "British Islands" alongside the dependency's respective name. They can become "full" EU citizens by moving to and living permanently in the United Kingdom or in Denmark, as the case may be.
British citizens however bearing passports from the Crown dependencies, but having sufficient connections to the UK proper, or to Gibraltar, are considered EU citizens. In June 2016, the United Kingdom European Union membership referendum saw the UK vote to leave the European Union, and therefore its citizens may lose their EU Citizen status in future, although the exact changes have yet to be defined and negotiated.
These four countries are not EU or EFTA members, and only Vatican City grants (time-limited) dual citizenship (see above). Andorra, Monaco, and San Marino forbid it. In 2012, however, 78% of the 36,000 inhabitants of Monaco were foreigners and not citizens. See also Andorran nationality law and nationality law of Monaco.

EFTA countries

Iceland - allows dual citizenship. See also Icelandic nationality law.
Liechtenstein - allows citizens by descent to have dual citizenship, but foreigners wanting to naturalize must renounce their old citizenship.
Norway - allows dual citizenship only in exceptional cases. A Norwegian citizen who voluntarily acquires another citizenship automatically loses Norwegian citizenship without notification, and foreigners wanting to naturalize must usually renounce their old citizenship. For details, see Norwegian nationality law - Dual citizenship.
Switzerland - allows dual citizenship, but the conditions for the naturalization of foreigners vary from canton to canton. Male Swiss citizens under the age of 25, including male dual citizens, are required to perform military or civilian service (women can do it voluntarily), and Swiss citizens (men and women) are not allowed to work for a foreign (non-Swiss) military. Foreign military service is a felony for Swiss citizens. (The Swiss Guards of Vatican City are regarded as a "house police", not an army.) In the Canton of Schaffhausen, voting is compulsory. For more details, see Swiss nationality law and Schweizer Bürgerrecht (in German).

The Nordic Passport Union

The Nordic Passport Union allows citizens of Denmark (including the Faroe Islands), Sweden, Norway, Finland, and Iceland to travel and reside in other Nordic countries without a passport or a residence permit. Norway restricts dual citizenship.

Partial citizenship

Many countries allow foreigners or former citizens to live and work indefinitely there. However, for voting, being voted and working for the public sector or the national security in a country, citizenship of the country concerned is almost always required.

In 2005, India amended the 1955 Citizenship Act to introduce a form of overseas citizenship,[42] which stops just short of full dual citizenship and is, in all aspects, like permanent residency.[43] Such overseas citizens are exempt from the rule forbidding dual citizenship; they may not vote, run for office, join the army, or take up government posts, though these evolving principles are subject to revolving political discretions for those born in India with birthrights. Moreover, people who have acquired citizenship in Pakistan or Bangladesh are not eligible for Overseas Citizenship.
For more details, see Permanent resident

Multiple citizenship "not recognized"

Saying that a country "does not recognize" multiple citizenship is a confusing and ambiguous term. Often, it is simply a restatement of the Master Nationality Rule, which means that a country treats a multiple-citizen, one of whose citizenships include that country's, no differently from a sole-citizen of that country. In other words, the country "does not recognize" that this multiple-citizen person has multiple citizenships, for the purposes of the country's laws, even though the person may actually be regarded as a citizen by other countries according to their laws. In particular, this may mean that citizens of that country cannot use another country's passport or citizenship documents to enter or leave the country.

Different countries allow dual citizenship for certain countries, but will not recognize dual citizenship of another country. For example, a Greek citizen will be allowed to have both Greek and US citizenship after naturalization, but Norwegian citizen will not be allowed to have both Norwegian and US citizenship.[45]

"Dormant" citizenship and "right of return"

The concept of a "dormant citizenship" means that a person has the citizenships of two countries, but as long as he/she lives permanently in the one country, his/her status and citizens' rights in the other country are "inactive." They will be "reactivated" when he/she moves back to and lives permanently in the other country. This means, in spite of dual citizenship, only one citizenship can be exercised at a time.

The "dormant citizenship" exists for example in Spain: Spanish citizens who have naturalized in an Iberoamerican country and have kept their Spanish citizenship are technically dual citizens, but have lost their rights as Spanish—and EU—citizens until they move back to and live permanently in Spain. Some countries offer former citizens or citizens of former colonies of the country a simplified (re-)naturalization process. Depending on the laws of the two countries in question, dual citizenship is allowed or not. For details, see "right of return".[46]

Multiple citizenship encouraged

Some countries are more open to multiple citizenship than others, as it may help citizens travel and conduct business overseas. Countries that have taken active steps towards permitting multiple citizenship in recent years include Switzerland (since January 1, 1992) and Australia (since April 4, 2002).[47][48]

Today, most advanced economies allow dual citizenship;[49] notable exceptions which restrict or forbid it are Austria, Germany, Japan, the Netherlands, Norway, Singapore, South Korea, and Spain. Of the newly industrialized countries, Brazil, Mexico, the Philippines, South Africa (with prior permission), Thailand, and Turkey (with prior permission) allow dual citizenship (Mexico does not allow their citizens to renounce their citizenship), while China (although Permanent Residents of Hong Kong and Macau may concurrently hold foreign passports), India, and Malaysia forbid it (but all Malaysian and some Indian citizens are Commonwealth citizens and are entitled to certain rights in the UK and other Commonwealth countries; India allows overseas citizenship – see above). Indonesia allows dual citizenship only until the age of 18 years.

In former times, some countries (Latin American countries and Canada) advertised their policy of unconditional birthright citizenship to become more attractive for immigrants. Despite wide acceptance of dual citizenship, industrialized countries now try to protect themselves from birth tourism and uncontrollable immigration waves, so only Canada and the United States still grant unconditional birthright citizenship (even for children of illegal immigrants). In both countries, there have been calls to change the laws, but, so far, they have not been successful. Brazil has similar policies; the only people born in Brazil who do not have Brazilian citizenship are the children of foreigners who abide Brazil while servicing their own country (such like diplomats, military attaché, cultural attaché and similars).

In Australia, France, Germany, Ireland, New Zealand, South Africa, and the UK, a child born there is regarded as a citizen only if at least one parent is either a citizen or a legal permanent resident who has lived there for several years. (Germany usually restricts dual citizenship, so non-EU/non-Swiss citizens born and grown up abroad must usually renounce their old citizenship when naturalizing.) Some countries (e.g. Liechtenstein) allow only citizens by descent to have dual citizenship, but require naturalized citizens to renounce their old citizenship.

Dual citizenship by region

Some African countries restrict or forbid dual citizenship.
It is allowed for example in Angola, Burundi, Côte d'Ivoire, Djibouti, Gabon, Gambia, Ghana, Kenya, Mali, Morocco, Mozambique, Niger, Nigeria, Rwanda, Senegal, São Tomé and Príncipe, Sierra Leone, Sudan, Tunisia, Uganda and Zambia.
Eritreans, Egyptians, and South Africans[21] wanting to take another citizenship need a permission to maintain their citizenship. Eritrea taxes its citizens worldwide, even if they have never lived in the country.
Lesotho restricts dual citizenship, but observes jus soli.
Most American countries allow dual citizenship (some only for citizens by descent or with other American countries with which they have agreements). Some countries (e.g., Argentina, Bolivia, Costa Rica) do not allow their citizens to renounce their citizenship, so they keep it even when naturalizing in a country that forbids dual citizenship. Most American countries observe unconditional jus soli, i.e. a child born there is regarded as a citizen even if the parents are not. Some countries (Dominican Republic, Ecuador, Guatemala, Honduras, Mexico, Nicaragua, Uruguay) allow renunciation of citizenship only if it was involuntarily acquired by birth to non-citizen parents.
Canada and the United States allow dual citizenship and are worldwide the only two developed economies to grant unconditional birthright citizenship. The United States taxes its citizens and Green-Card holders worldwide, even if they have never lived in the country. In 2014, the U.S. Department of State increased the fee for processing requests for renunciation of citizenship from $450 to $2,350.[50][51]
Dual citizenship is restricted or forbidden, for example, in Cuba, Haiti and Suriname.
Most countries in the Asia-Pacific region restrict or forbid dual citizenship. But in some of these countries (e.g. Iran, North Korea, Thailand), it is very difficult or even impossible for citizens to renounce their citizenship, even when naturalizing in another country.
Dual citizenship is allowed for example in Australia, Fiji, New Zealand, Philippines, Samoa, Tonga, and Vanuatu.[52]
Cambodia allows dual citizenship and observes jus soli for children born to legal permanent residents born in Cambodia or to children whose parents are unknown.
South Korea allows dual citizenship in limited circumstances. It allows foreign born nationals who married to a Korean citizen, Korean men holding dual citizenship by birth who served in the Republic of Korea Armed Forces as compulsory military service, Korean women with multiple nationalities by birth who has vowed her intention not to exercise her foreign nationality in the Republic of Korea by the age of 22 and overseas Koreans at least 65 years of age.[53]
Taiwan[54] and Hong Kong allow dual citizenship for citizens by birth, but do not permit applicants for naturalization to retain their prior citizenship.
Burmese nationality law forbids its citizens to have dual citizenship, and foreigners cannot become naturalized citizens, unless they can prove a close familial connection to the country
Pakistan restricts dual citizenship (see above), but observes jus soli.
In Papua New Guinea there was overwhelming support from parliament to amend their Constitution to allow dual citizenship, however the law had yet to come into force as of February 2014.[55]
Sri Lanka allows dual citizenship. However, under the 19th amendment of that country's constitution, dual citizens are not allowed to hold public office.
Israel allows dual citizenship.
Indian constitution does not allow voluntary Dual Citizenship.[56] However, in response to persistent demands for dual citizenship, particularly from the diaspora in North America and other developed countries, The Overseas Citizenship of India (OCI) scheme was introduced by amending The Citizenship Act, 1955 in August 2005.[57]
Albania, Belarus, Moldova,[58] Russia[59] and Serbia[60] allow dual citizenship. But in Russia, a second citizenship must be reported.
Bosnia, Macedonia, and Montenegro generally do not allow dual citizenship.
Ukrainian law currently does not recognise dual citizenship. However there are citizens of Ukraine who hold dual citizenship. This includes state officials such as Igor Kolomoisky, who holds three citizenships. On February 8, 2014, the Rada proposed a bill to criminalize the act of holding two citizenships.[61]

Effects of multiple citizenship

It is often observed that dual citizenship may strengthen ties between migrants and their countries of origin and increase their propensity to remit funds to their communities of origin.[62]

Qualitative research on the impact of dual citizenship on the remittances, diaspora investments, return migration, naturalization and political behavior finds several ways in which multiple citizenship can affect these categories. As a bundle of rights, dual citizenship (a) enables dual citizens by granting special privileges, (b) affects their expectations about privileges in the decision-making process, and (c) eases the transaction process and reducing costs and risks, for example in the case of investing and conducting business.[63] In addition, a dual legal status can have positive effects on diasporic identification and commitment to causes in the homeland, as well as to a higher naturalization rate of immigrants in their countries of residence.[64]

Subnational citizenship


Supra-national citizenship

Potential issues

National cohesiveness

Some have questioned whether allowing dual citizenship impedes cultural assimilation or social integration, increases disconnection from the political process, and degrades national or civic identity/cohesiveness.[72]

The rise in tension between mainstream and migrant communities is cited as evidence of the need to maintain a strong national identity and culture. They assert that the fact that a second citizenship can be obtained without giving anything up (such as the loss of public benefits, welfare, healthcare, retirement funds, and job opportunities in the country of origin in exchange for citizenship in a new country) both trivializes what it means to be a citizen[73] and nullifies the consequential, transformational, and psychological change that occurs in an individual when they go through the naturalization process.[74]

In effect, this approach argues, the self-centered taking of an additional citizenship contradicts what it means to be a citizen in that it becomes a convenient and painless means of attaining improved economic opportunity without any real consequences and can just as easily be discarded when it is no longer beneficial.[75] Proponents argue that dual citizenship can actually encourage political activity providing an avenue for immigrants who are unwilling to forsake their country of origin either out of loyalty or due to a feeling of separation from the mainstream society because of language, culture, religion, or ethnicity.[76]

A 2007 academic study concluded that dual citizens had a negative effect on the assimilation and political connectedness of first-generation Latino immigrants to the United States:

The study also noted that although dual nationality is likely to disconnect immigrants from the American political system and impede assimilation, the initial signs suggest that these effects seem to be limited almost exclusively to the first generation (although it is mentioned that a full assessment of dual nationality beyond the first generation is not possible with present data).[77]

Concern over the effect of multiple citizenship on national cohesiveness is generally more acute in the United States. The reason for this is twofold:

The degree of angst over the effects of dual citizenship seemingly corresponds to a country's model for managing immigration and ethnic diversity:

Appearance of foreign allegiance

People with multiple citizenship may be viewed as having dual loyalty, having the potential to act contrary to a government's interests, and this may lead to difficulties in acquiring government employment where security clearance may be required.

In the United States, dual citizenship is associated with two categories of security concerns: foreign influence and foreign preference. Contrary to common misconceptions, dual citizenship in itself is not the major problem in obtaining or retaining security clearance in the United States. As a matter of fact, if a security clearance applicant's dual citizenship is "based solely on parents' citizenship or birth in a foreign country", that can be a mitigating condition.[83] However, taking advantage of the entitlements of a non-US citizenship can cause problems. For example, possession or use of a foreign passport is a condition disqualifying one from security clearance and "is not mitigated by reasons of personal convenience, safety, requirements of foreign law, or the identity of the foreign country" as is explicitly clarified in a Department of Defense policy memorandum which defines a guideline requiring that "any clearance be denied or revoked unless the applicant surrenders the foreign passport or obtains official permission for its use from the appropriate agency of the United States Government".[84]

This guideline has been followed in administrative rulings by the United States Department of Defense (DoD) Defense Office of Hearings and Appeals (DOHA) office of Industrial Security Clearance Review (ISCR), which decides cases involving security clearances for Contractor personnel doing classified work for all DoD components. In one such case, an administrative judge ruled that it is not clearly consistent with US national interest to grant a request for a security clearance to an applicant who was a dual national of the US and Ireland, despite the fact that it has with good relations with the US.[85]

In Israel, certain military units, including most recently the Israeli Navy's submarine fleet, as well as posts requiring high security clearances, require candidates to renounce any other citizenship before joining, though the number of units making such demands has declined. In many combat units, candidates are required to declare but not renounce any foreign citizenship.[86]

On the other hand, Israel may view some dual citizens as desirable candidates for its security services due to their ability to legitimately enter neighbouring states which are closed to Israeli passport holders. The related case of Ben Zygier has caused debate about dual citizenship in Australia.[87]

Multiple citizenship among politicians

This perception of dual loyalty can apply even when the job in question does not require security clearance. In the United States, dual citizenship is common among politicians or government employees. For example, Arnold Schwarzenegger retained his Austrian citizenship during his service as a Governor of California[88] while US Senator Ted Cruz renounced his Canadian citizenship birthright on May 14, 2014.[89][90]

In 1999, the US Attorney General's office issued an official opinion that a statutory provision that required the Justice Department not to employ a non-"citizen of the United States"[91] did not bar it from employing dual citizens.[92]

In Germany, politicians can have dual citizenship. David McAllister, who holds British and German citizenship, was minister president of the State of Lower-Saxony from July 1, 2010 to February 19, 2013. He was the first German minister president to hold dual citizenship.

A small controversy arose in 2005 when Michaëlle Jean was appointed the Governor General of Canada (official representative of the Queen). Although Jean no longer holds citizenship in her native Haiti, her marriage to French-born filmmaker Jean-Daniel Lafond allowed her to obtain French citizenship several years before her appointment. Article 23-8[93] of the French civil code allows the French government to withdraw French nationality from French citizens holding government or military positions in other countries and Jean's appointment made her both de jure head of state and commander-in-chief of the Canadian forces. The French embassy released a statement that this law would not be enforced because the Governor General is essentially a ceremonial figurehead. Nevertheless, Jean renounced her French citizenship two days before taking up office to end the controversy about it.[94]

However, former Canadian Prime Minister John Turner was born in the United Kingdom and still retains his dual citizenship. Stéphane Dion, former head of the Liberal Party of Canada and the previous leader of the official opposition, holds dual citizenship with France as a result of his mother's nationality; Dion nonetheless indicated a willingness to renounce French citizenship if a significant number of Canadians viewed it negatively.[95] Thomas Mulcair, Leader of the New Democratic Party and former leader of Official Opposition in the Canadian House of Commons also holds dual citizenship with France.

In Egypt, dual citizens cannot be elected to Parliament.

The Constitution of Australia, in Section 44(i), explicitly forbids people who hold foreign citizenship from sitting in the parliament of Australia.[96] A court case (see Sue v Hill) determined that the UK is a foreign power for purposes of this section of the constitution, despite Australia holding a common nationality with it at the time that the Constitution was written, and that Senator-elect Heather Hill had not been duly elected to the national parliament because at the time of her election she was a subject or citizen of a foreign power. However, the High Court of Australia also ruled that dual citizenship on its own would not be enough to disqualify someone from validly sitting in Parliament. The individual circumstances of the non-Australian citizenship must be looked at although the person must make a reasonable effort to renounce his or her non-Australian citizenship. However, if that other citizenship cannot be reasonably revoked (for example, if it is impossible under the laws of the other country or impossible in practice because it requires an extremely difficult revocation process), then that person will not be disqualified from sitting in Parliament.[97] (This restriction on people with dual or multiple citizenship being members of parliament does not apply to the state parliaments, and the regulations vary by state.)

In New Zealand, controversy arose in 2003 when Labour MP Harry Duynhoven applied to renew his citizenship of the Netherlands. Duynhoven, the New Zealand-born son of a Dutch-born father, had possessed dual citizenship from birth but had temporarily lost his Dutch citizenship due to a 1995 change in Dutch law regarding non-residents.[98] While New Zealand's Electoral Act allowed candidates with dual citizenship to be elected as MPs, Section 55[99] of the Act stated that an MP who applied for citizenship of a foreign power after taking office would forfeit his/her seat. This was regarded by many as a technicality, however; and Duynhoven, with his large electoral majority, was almost certain to re-enter Parliament in the event of a by-election. As such, the Labour Government retrospectively amended the Act, thus enabling Duynhoven to retain his seat. The amendment, nicknamed "Harry's Law",[100] was passed by a majority of 61 votes to 56.[101] The revised Act allows exceptions to Section 55 on the grounds of an MP's country/place of birth, descent, or renewing a foreign passport issued before the MP took office.[102]

Both the former Estonian president Toomas Hendrik Ilves and the former Lithuanian president Valdas Adamkus had been naturalized US citizens prior to assuming their offices. Both have renounced their US citizenships: Ilves in 1993 and Adamkus in 1998. This was necessary because neither individual's new country permits retention of a former citizenship. Adamkus was a high-ranking official in the Environmental Protection Agency, a federal government department, during his time in the United States. Former Latvian president Vaira Vīķe-Freiberga relinquished Canadian citizenship upon taking office in 1999.[103]


In some cases, multiple citizenship can create additional tax liability. Most countries that impose tax normally base tax liability on source or residency. Some countries tax their non-resident citizens on foreign income; examples include the United States and Eritrea.[104]

Only US expatriates (who have not renounced citizenship) are subject to tax on all of their worldwide income, although US law provides measures to reduce or eliminate double taxation issues for some expatriates. It has been reported that some US expatriates have renounced US citizenship in order to avoid this tax burden.[105][106]

A person with multiple citizenship may have a tax liability to his country of residence and also to one or more of his countries of citizenship; or worse, if unaware that one of his citizenships created a tax liability, that country may consider the person to be a tax evader. Many countries and territories have contracted tax treaties or agreements for avoiding double taxation. Still, there are cases in which a person with multiple citizenship will owe tax solely on the basis of holding one such citizenship.

For example, consider a person who holds both Australian and United States citizenship, lives and works in Australia. He would be subject to Australian taxation, because Australia taxes its residents, and he would be subject to US taxation because he holds US citizenship. In general, he would be allowed to subtract the Australian income tax he paid from the US tax that would be due. Plus, the US will allow some parts of foreign income to be exempt from taxation; for instance, in 2006 the foreign earned income exclusion allowed up to US$82,400 of foreign salaried income to be exempt from income tax (in 2014, this has now increased to US$97,600).[107] This exemption, plus the credit for foreign taxes paid mentioned above, often results in no US taxes being owed, although a US tax return would still have to be filed. In instances where the Australian tax was less than the US tax, and if there was income that could not be exempted from US tax, the US would expect any tax due to be paid.

The United States Internal Revenue Service has excluded some regulations such as Alternative Minimum Tax (AMT) from tax treaties that protect double taxation. In its current format even if US citizens are paying income taxes at a rate of 56%, far above the maximum US marginal tax rate, the citizen can be subject to US taxes because the calculation of the Alternative Minimum Tax does not allow full deduction for taxes paid to a foreign country. Other regulations such as the post date of foreign mailed tax returns are not recognized and can result in penalties for late filing if they arrive at the IRS later than the filing date. However, the filing date for overseas citizens has a two-month automatic extension to June 15.[108]

"If you are a U.S. citizen or resident alien residing overseas, or are in the military on duty outside the U.S., on the regular due date of your return, you are allowed an automatic 2-month extension to file your return and pay any amount due without requesting an extension. For a calendar year return, the automatic 2-month extension is to June 15. If you are unable to file your return by the automatic 2-month extension date, you can request an additional extension to October 15 by filing Form 4868 before the automatic 2-month extension date. However, any tax due payments made after June 15 will be subject to both interest charges and failure to pay penalties." (IRS, 2012)

Issues with international travel

Many countries, even those that permit multiple citizenship, do not explicitly recognise multiple citizenship under their laws: individuals are treated either as citizens of that country or not, and their citizenship with respect to other countries is considered to have no bearing. This can mean (in Iran,[109] Mexico,[110] many Arab countries, and former Soviet republics) that consular officials abroad may not have access to their citizens if they also hold local citizenship. Some countries provide access for consular officials as a matter of courtesy, but do not accept any obligation to do so under international consular agreements. The right of countries to act in this fashion is protected via the Master Nationality Rule.

Multiple citizens who travel to a country that claims them as a citizen may be required to enter or leave the country on that country's passport. For example, a United States Department of State web page on dual nationality contains the information that most US citizens, including dual nationals, must use a US passport to enter and leave the United States.[111] Under the terms of the South African Citizenship Act, it is an offence for someone aged at least 18 with South African citizenship and another citizenship to enter or depart the Republic of South Africa using the passport of another country. They may also be required, before leaving the country, to fulfill requirements ordinarily required of its resident citizens, including compulsory military service or exit permits.

In accordance with the proposed European Travel Information and Authorisation System (ETIAS) that is expected to enter into operation on 1 January 2020, the EU citizens who have multiple nationalities will be obliged to use the passport issued by an EU Member State for entering the Schengen area.[112]

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Further reading

External links

Council of Europe
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