Multiple citizenship

Template:Legal status Multiple citizenship is a status in which a person is concurrently regarded as a citizen under the laws of more than one state. Multiple citizenships exist because different countries use different, and not necessarily mutually exclusive, citizenship requirements. Colloquial speech refers to people "holding" multiple citizenship but technically each nation makes a claim that this person be considered its national. For this reason, it is possible for a person to be a citizen of one or more countries, or even no country.

Citizenship of multiple countries

Individual countries follow their own rationales in establishing their criteria for citizenship. Each country has different requirements and policies on both acquiring its citizenship and holding other citizenships concurrently. These laws sometimes create situations where someone may acquire other citizenships without rendering the original citizenship invalid, or where someone may satisfy the citizenship requirements of more than one country simultaneously through no action of his or her own (e.g. at birth). This would allow the individual to hold two or more nationalities. Here are common reasons to bestow citizenship:

• At least one parent is a citizen (jus sanguinis). Today, the citizenship laws of most countries in the world are based on jus sanguinis.
• The person was born on the country's territory (jus soli). Of the advanced economies, only Canada and the United States of America grant uncoditional birthright citizenship, other countries have abolished it to stop "birth tourism." Australia, France, Germany, Ireland, New Zealand, South Africa, and the United Kingdom have a modified jus soli (at least one parent must be a citizen or a legal permanent resident who has lived in the country for several years). Many Latin American countries still grant unconditional birthright citizenship.
• The person marries a citizen (jure matrimonii). Today, being married to a citizen of a country may shorten the time to naturalization, but only in a few countries is the new citizenship granted on the wedding day.
• The person becomes naturalized.
• The person was adopted from another country as a minor and at least one adoptive parent is a citizen.
• The person makes a substantial monetary investment: Austria, Cyprus, Dominica and St. Kitts & Nevis.
• Some countries grant citizenship based on religion: In Israel, the Law of Return defines that all Jews possessing an Oleh's certificate shall become Israel nationals and be allowed to immigrate to Israel. Such a certificate would almost automatically turn into Israeli citizenship upon arrival in Israel if so desired. In the 1970s the Law of Return was further expanded, and it was defined that the spouse of a Jew, the children of a Jew and their spouses, and the grandchildren of a Jew and their spouses would also be covered under the Law of Return and thus be eligible for an Oleh's certificate provided that the Jew on behalf of whom they request the certificate did not practice a religion other than Judaism willingly (he or she may, however, be a non-observant Jew). The Algerian nationality law, promulgated in 1963, granted citizenship only to Muslims, requiring that only those individuals whose fathers and paternal grandfathers had Muslim personal status could become citizens of the new state.
• In one case, citizenship is based on holding an office (jus oficii): Vatican citizenship is held by the Pope, cardinals residing in Vatican City, active members of the Holy See's diplomatic service, and other directors of Vatican offices and services. Vatican citizenship is lost when the office term is over, and children cannot inherit it from their parents. Since Vatican citizenship is time-limited, dual citizenship is allowed (Swiss Guards even must have dual citizenship with Switzerland), and persons who would be stateless after losing Vatican citizenship automatically become Italian citizens. Since March 1, 2011, a new law has allowed permanent residency in Vatican City.

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. However, this renunciation may not be recognized by the renounced country. Technically, the person in question may still possess both citizenships.

For example, United States Chief Justice John Rutledge ruled "a man may, at the same time, enjoy the rights of citizenship under two governments," but the US 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. In the case of a British citizen, however, the UK honors renunciation of citizenship only if done with competent UK authorities. Consequently, British citizens naturalized in the US remain British citizens in the eyes of the British government even after they renounce British allegiance to the satisfaction of U.S. authorities.

The Republic of Ireland frames its citizenship laws as relating to "the island of Ireland", thereby extending them 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 of Ireland but with a qualifying parent) may exercise an entitlement to Irish citizenship by acting in such a way that only an Irish citizen is entitled to do (such as applying for an Irish passport). Conversely, that such a person has not acted in this way does not necessarily mean that they are not entitled to be an Irish citizen. See Irish nationality law and British nationality law. People born in Northern Ireland are British citizens on the same basis as people born elsewhere in the United Kingdom. People born in Northern Ireland may choose to hold a British passport, an Irish passport, or both.

Multiple citizenship avoided

Some countries consider multiple citizenship undesirable and take measures to avoid it. Since a country only has control 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:

• Automatic loss of citizenship if another citizenship is acquired voluntarily (such as Azerbaijan, China, Czech Republic, Denmark, India, Indonesia, Japan, Kazakhstan, Nepal, the Netherlands, Norway). In the case of the Czech Republic, two specific exceptions apply: those who acquired other citizenship after being illegally deprived of citizenship by the Communist regime of 1948–1990, or whose Slovak citizenship as of September 31, 1992, caused automatic loss of Czech citizenship upon the partition of Czechoslovakia, may apply for restoration of Czech citizenship without losing another. However, in October 2012 the Czech Ministry of the Interior presented a draft of a revision of the Citizenship Act that, if passed by the Parliament, will inter alia (besides the existing options: by birth, through marriage, by means of restoration of one's citizenship in certain cases and by virtue of a statutory exception granted by the state authorities ) provide a new cause of obtaining dual citizenship on the basis of a voluntary acceptance of a foreign citizenship while retaining the Czech one. Thus, the Czech Republic would become one of those few EU member states (for example United Kingdom or Hungary) fully supporting dual citizenship regime. Saudi Arabian citizenship may be withdrawn if a Saudi citizen obtains a foreign citizenship without the permission of the Prime Minister.
• Possible (but not automatic) loss of citizenship if another citizenship is acquired voluntarily (such as Singapore, Malaysia, South Africa).
• Possible (but not automatic) loss of citizenship if people with multiple citizenships do not renounce their other citizenships after reaching the age of majority or within a certain period of time after obtaining multiple citizenships (such as Japan and Montenegro. In Montenegro loss is automatic with some exceptions.)
• Denying automatic citizenship from birth if the child may acquire another citizenship automatically at birth.
• Requiring an applicant for naturalization to apply to renounce his/her existing citizenship(s), and provide proof from those countries that they have renounced citizenship, as a condition of naturalization.

Complex laws on dual citizenship

Some countries do not simply allow or forbid dual or multiple citizenship in general, but have more complex rules on it.

For example,

• Some countries allow dual citizenship, but restrict the rights of dual citizens, e.g. in Australia and Egypt, dual citizens cannot be elected to Parliament; in the United States, naturalized citizens cannot run for the offices of President or Vice President, who must be "natural-born citizens," but they can hold any other office.

• Germany and Austria usually do not allow dual citizenship except for persons who obtain more than one citizenship at the time of birth. Germans and Austrians can apply for a permission to keep their citizenship (Beibehaltungsgenehmigung) before taking a second one (for example, both Austria and the U.S. consider Arnold Schwarzenegger a citizen). In general however, any Austrian who takes up a second citizenship will automatically lose Austrian citizenship. Since August 2007, Germany has accepted dual citizenship if the other citizenship is either one of an EU member country or a Swiss citizenship so that a permission is not required anymore in these cases, and in some exceptional cases, non-EU- and non-Swiss citizens can keep their old citizenship when they become citizens of Germany. For more details, see German nationality law#Dual citizenship. Changes of the German law on dual citizenship are being discussed, according to which children of non-EU legal permanent residents can have dual citizenship if born and grown up in Germany.

• Acquisition of the nationality of Latin American countries, Andorra, the Philippines, Equatorial Guinea or Portugal is not sufficient to cause the loss of Spanish nationality by birth. Spain has dual citizenship treaties with Argentina, Bolivia, Chile, Colombia, Costa Rica, the Dominican Republic, Ecuador, Honduras, Guatemala, Nicaragua, Paraguay, and Peru; Spaniards residing in these countries do not lose their rights as Spaniards if they adopt that nationality. For all other countries, Spanish citizenship is lost three years after the acquisition of the foreign citizenship unless the individual declares officially their will to retain Spanish citizenship (Spanish Nationality Law). Upon request Spain has allowed persons from Puerto Rico to acquire Spanish citizenship. On the other hand, foreign nationals that acquire the Spanish nationality lose their previous nationality, unless they were natural born citizens of an Iberoamerican country, Andorra, the Philippines, Equatorial Guinea or Portugal, even if these countries do not grant their citizens a similar treatment.

• Prior to 2011, South Korea did not permit dual citizenship after the age of 21. Now a limited number of persons can have it. For details, see South Korean nationality law#Dual citizenship.

• Like Germans and Austrians, citizens of South Africa must apply for a permission to keep their citizenship, or they will lose their South African citizenship when acquiring the citizenship of another country.

• The Turkish government requires that Turkish citizens who apply for another nationality inform the appropriate Turkish officials (the nearest Turkish embassy or consulate abroad) and provide the original naturalization certificate, Turkish birth certificate, document showing completion of military service (for males), marriage certificate (if applicable) and four photographs. Dual nationals are not compelled to use a Turkish passport to enter and leave Turkey; it is permitted to travel with a valid foreign passport and the Turkish National ID card.

• Pakistan allows dual citizenship only with 16 countries: Australia, Belgium, Canada, Egypt, France, Iceland, Ireland, Italy, Jordan, Netherlands, New Zealand, Sweden, Switzerland, Syria, United Kingdom, and United States.

The dual-citizenship policies of the 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.)

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

• Currently (October 2013), the following 14 EU countries restrict or forbid dual citizenship:

Austria (see above; dual citizenship is possible with special permission or if it was obtained at birth)

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)

Czech Republic (forbids dual citizenship unless the non-Czech citizenship was obtained by birth or by marriage)

Denmark (currently, it is a fundamental principle in the legislation to restrict dual nationality as much as possible. One exception to this is if a person is born of a Danish parent in a country that grants citizenship under the principle of jus soli; a law to allow dual citizenship is being discussed)

Estonia (forbids dual citizenship, but citizens by descent cannot be deprived of their Estonian citizenship, so they de facto can have 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; changes of the dual-citizenship law are being discussed, according to which children of non-EU legal permanent residents can have dual citizenship if born and grown up in Germany)

Ireland (allows 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 permanent resident)

Latvia (starting from October the 1st, 2013 dual citizenship with Latvia is 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 had 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 (the Lithuanian Constitution states in Article 12 that only in "individual cases provided for by law" can dual citizenship be permitted. [Constitution of the Republic of Lithuania, adopted on Oct. 25, 1992, in force from Nov. 2, 1992])

Netherlands (dual citizenship is allowed under certain conditions: e.g. foreign citizenship may be kept in the event of naturalization via marriage)

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)

Slovak Republic (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)

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)

• EU countries currently having no specific rules on dual citizenship:

Poland (Polish law 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)

• The special case of Cyprus / Northern Cyprus:

Cyprus allows dual citizenship.

Northern Cyprus is not generally recognized by the international community (the EU regards the island of Cyprus as indivisible and sees Northern Cyprus as a "special region" and not as an independent country). The main country, and probably the only one, that recognizes Northern Cyprus is Turkey. Thus, a Northern Cyprus passport is not accepted as a valid travel document in most countries (exceptions: Australia, France, Syria, United Kingdom, United States, and Turkey). Citizens of Northern Cyprus are permitted to live and work in Turkey under the same requirements as Turkish citizens. Turkey provides a special type of passport for Northern Cyprus citizens. Despite the ethnic and physical division of Turkish Cypriots from the rest of Cyprus, they can obtain Cypriot passports and ID cards if they prove to be Cypriots by descent. Turkish settlers in the northern part of Cyprus are not entitled to Cypriot citizenship.

• British and Danish citizens not regarded as EU citizens:

The Channel Islands of Guernsey and Jersey and the Isle of Man are British territories, but no parts of the EU.

The Faroe Islands belong to Denmark, but not the EU, so their inhabitans are Danish citizens, but not EU citizens. Greenland left the EC in 1985, but Greenlanders are considered EU citizens.

These British and Danish citizens get "local" passports (in practice, citizens of Faroe Islands and Greenland can choose between local and "European" passports); they can become "full" EU citizens by moving to and living permanently in the United Kingdom or in Denmark.

Greenland plans to become an independent country. If this happens, Greenlanders will lose their Danish—and EU—citizenship.

• EU-candidate countries (Macedonia, Montenegro, Serbia, and Turkey):

Macedonia allows dual citizenship only in exceptional cases.

Montenegro forbids dual citizenship, but citizens of descent cannot be deprived of their citizenship, so they de facto can have it.

Serbia allows dual citizenship.

Turkey allows dual citizenship, but Turkish citizens must inform the authorities before they can take a second citizenship. For former Turkish citizens, the "Blue Card" (Mavi Kart) was created, which gives them the right to live and work in Turkey (See the sections about complex laws and "partial" citizenship).

• Bosnia-Herzegovina and Kosovo:

These two other successor states of Yugoslawia are no EU or EFTA members; both allow dual citizenship, but not all countries recognize Kosovo and a Kosovar passport.

• The four microstates surrounded by EU countries (Andorra, Monaco, San Marino, and Vatican City):

These four countries are no 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.

• EFTA countries (Iceland, Liechtenstein, Norway, Switzerland):

Iceland allows dual citizenship.

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, including male dual citizens, can be 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. (The Swiss Guards of Vatican City are regarded as a "house police" and not as 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 the Nordic countries of Denmark (Faroe Islands included), Sweden, Norway, Finland, and Iceland to travel and reside in other Nordic countries without a passport or a residence permit. However, Denmark and Norway restrict/forbid 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.

• Since 2008, Poland has granted the "Polish Card" (Karta Polaka) to ethnic Poles who are citizens of the successor states of the former Soviet Union and can prove they have Polish ancestors and knowledge of the Polish language and declare their Polish ethnicity in written form. Holders of the Card are not regarded as citizens, but enjoy some privileges other foreigners do not, e.g. entry visa, right on work, education, or healthcare in Poland. As stated above, Poland currently has no specific laws on dual citizenship; a second citizenship is tolerated, but not recognized.

• Turkey allows its citizens to have dual citizenship if they inform the authorities before acquiring the second citizenship (see above), and former Turkish citizens who have given up their Turkish citizenship (for example, because they have naturalized in a country that usually does not permit dual citizenship, such as Germany, Austria or the Netherlands) can apply for the "Blue Card" (Mavi Kart), which gives them some citizens' rights back, e.g. the right to live and work in Turkey, the right to possess land or the right to inherit, but not, for example, the right to vote.

• Overseas citizenship of India: The Constitution of India does not permit dual citizenship or dual nationality, except for minors where the second nationality was involuntarily acquired. Indian authorities interpreted this to mean a person cannot have another country's passport while simultaneously holding an Indian one, even for a child claimed by another country as its citizen, who may be required by the laws of this country to use the corresponding passports for foreign travel (such as a child born in the United States to Indian parents). Indian courts have given the executive branch wide discretion over this matter.

In 2005, India amended the 1955 Citizenship Act to introduce a form of overseas citizenship, which stops just short of full dual citizenship and is, in all aspects, like permanent residency. 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 if you are born in India with birthrights. Moreover, people who have acquired citizenship in Pakistan or Bangladesh are not eligible for Overseas Citizenship.

• Many countries (e.g. USA, Canada, all EU countries and Switzerland, Australia, New Zealand) allow permanent residency for foreigners, i.e. they can live and work in the country indefinitely, but they are subject to certain limitations (e.g. no right to vote or to be voted, no consular protection) and obligations. Usually, permanent residents can apply for citizenship after several years of residency in the country concerned. Depending both on the home country and the guest country, dual citizenship may or may not be permitted; in the latter case, permanent residents sometimes prefer not to naturalize, but to maintain their current status.

For more details, see Permanent resident

• Some countries have concluded treaties regulating travel and access to the job markets (non-government/non-military-related work): 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 in EU countries). The "Trans-Tasman Travel Agreement" between Australia and New Zealand allows citizens of the two countries to live and work in each other's neighboring country. A citizen of a GCC member state (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and United Arab Emirates) can live and work in other member states, but dual citizenship (even with another GCC state) is not allowed. Indian citizens do not need a visa to travel to and work in Nepal or Bhutan, but none of the three countries allows dual citizenship.

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 is that country's, no differently than a sole-citizen of that country. In other words, the country "does not recognize" 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 if you're a citizen of that country, you cannot use another country's passport or citizenship documents to enter or leave the country.

"Dormant" citizenship

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 restored 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 passport are technically dual citizens, but have lost their rights as Spanish—and EU—citizens until they move back to and live permanently in Spain.

Multiple citizenship encouraged

Some countries consider multiple citizenship desirable as it increases opportunities for their citizens to compete globally, and/or have taken active steps towards permitting multiple citizenship in recent years (such as Switzerland since 1 January 1992 and Australia since 4 April 2002).
Today, most advanced economies allow dual citizenship; notable exceptions that restrict or forbid it are Austria, Denmark, Germany, Japan, the Netherlands, Norway, Singapore, South Korea, and Spain.
In spite of wide support of dual citizenship, industrialized countries try to protect themselves from "birth tourism" and uncontrollable immigration waves, so only Canada and the United States of America still grant unconditional birthright citizenship in combination with dual citizenship. In Australia, France, Germany, Ireland, New Zealand, South Africa, and the United Kingdom, a baby 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.)
In former times, some countries (Latin American countries, also Canada) advertized their policy of unconditional birthright citizenship to become more attractive for immigrants.
Some countries (e.g. Liechtenstein) allow only citizens by descent to have dual citizenship, but require naturalized citizens to renounce their old citizenship.

Multiple citizenship required

The Pontifical Swiss Guard are required to be citizens of both Switzerland and the Vatican City. They lose their Vatican citizenship once their service with the Guard is finished.

Dual citizenship by continents

Since laws are subject to change, it is advisable before taking a new citizenship to verify whether the current laws of both the home country and the guest country allow dual citizenship.

• Africa:

Most 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, Rwanda, Senegal, São Tomé and Príncipe, Sierra Leone, Sudan, Tunisia, and Uganda.

Eritreans, Egyptians, and South Africans wanting to take another citizenship need a permission to maintain their citizenship.

Lesotho restricts dual citizenship, but observes jus soli.

• The Americas:

Most American countries allow dual citizenship (some only for citizens by descent and / or with other American countries with which they have agreements). Some countries (e.g. Argentina, Bolivia, Brazil, 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 baby 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 of America allow dual citizenship and are worldwide the two only advanced economies to grant unconditional birthright citizenship, which has led to "birth tourism."

Dual citizenship is resticted or forbidden for example in Cuba and Suriname.

• Asia-Pacific:

Most countries in the Asian-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, Taiwan.

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.

The Special Administrative Region of Hong Kong allows dual citizenship, unlike mainland China, and grants the right of abode to all Chinese citizens born there, which has led to "birth tourism" from mainland China.

Israel allows dual citizenship, but most Muslim countries do not recognize Israel and reject Israeli passports and/or any passports with Israeli visa stamps. Among the Muslim countries that accept the Israeli passport are Egypt, Morocco, Tunisia, and Turkey.

Pakistan restricts dual citizenship (see above), but observes jus soli.

In Papua New Guinea and Vanuatu, laws allowing dual citizenship are currently being discussed.

• Europe:

Europe is divided over dual citizenship: In about half of the countries, it is allowed; in the other half, it is restricted or forbidden.

For EU, EFTA, EU candidate countries (including Turkey), Bosnia-Herzegowina, Kosovo, and the European microstates, see above.

The rest of Europe:

Albania, Armenia, Moldova, and Russia allow dual citizenship,

Belarus forbids it, Georgia allows it only in exceptional cases,

Ukraine accepts dual citizenship, but does not recognize it.

Subnational citizenship

• Under the Fourteenth Amendment to the United States Constitution, all persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they are deemed to reside. Certain rights accrue as an incident of state citizenship and access to federal courts can sometimes be determined on State citizenship.
• Switzerland has a three tier system of citizenship - Confederation, canton and commune (municipality).
• Although considered part of the United Kingdom for British nationality purposes, the Crown Dependencies of Jersey, Guernsey and the Isle of Man have local legislation restricting certain employment and housing rights to those with "local status". Although the British citizenship of people from these islands gives them full citizenship rights when in the United Kingdom, it does not give them the rights that British citizenship generally confers when in other parts of the European Union (for example, the right to reside and/or work).
• The Australian territory of Norfolk Island has immigration laws that restrict residence in the territory to those with "local status". Most Norfolk Islanders are Australian citizens.
• The statuses of permanent residency of Hong Kong and Macau, each a Special Administrative Region of the People's Republic of China, are overlaid on Chinese nationality as stipulated in their respective basic laws. Those who concurrently have Chinese nationality and permanent residency in either SAR are entitled a Chinese passport issued by that SAR, which affords them more visa waivers. Laws may confer specific rights to certain persons by virtue of being a Chinese national (such as the right to transmit nationality by birth), a resident (permanent or all) of the region (e.g. right to vote in local elections), or a combination of both (such as the right to hold public office above a certain level). It is now possible to be a permanent resident of both Special Administrative Regions.
• People from Åland have joint regional (Åland) and national (Finnish) citizenship. People with Ålandic citizenship (hembygdsrätt) have the right to buy property and set up a business on Åland, but Finns without regional citizenship cannot. Finns can get Ålandic citizenship after living on the islands for five years, and Ålanders lose their regional citizenship after living on the Finnish mainland for five years.
• The government of Puerto Rico began issuing Puerto Rican citizenship certificates in September 2007 after Juan Mari Brás, a lifelong supporter of independence, won a successful court victory that validated his claim that Puerto Rican citizenship was valid and can be claimed by anyone born on the island or with at least one parent who was born there.
• In Bosnia and Herzegovina, citizens hold also citizenship of their respective entity which is generally the Entity of their residence. It can be either citizenship of Republika Srpska or of the Federation of Bosnia and Herzegovina. One cannot hold both entity citizenships simultaneously.

Former

• Following the federalization of Czechoslovakia in 1968, Czechoslovak citizens also possessed an internal citizenship of either the Czech or Slovak Republic. Upon the nation's peaceful dissolution in 1993, this was used to determine whether they ought to receive Czech or Slovak citizenship.
• Before the break-up of Yugoslavia in 1991, Yugoslav citizens possessed an internal citizenship of their own republic (Serbia, Croatia, Bosnia and Herzegovina, Slovenia etc.) as well as Yugoslav citizenship. In Serbia and Montenegro, this system was in effect until 2006.

Supra-national citizenship

• In European Union law there is the concept of EU citizenship which flows from citizenship of a member state. A citizen of an EU country is free to live and to work in another EU country for an unlimited period of time, but member states may reserve the right to vote in national elections, stand for national election, become a public servant in highly sensitive ministries (Defence for example), etc. only for their citizens. An EU state may place restrictions on the free movement rights of citizens of newly admitted states for several years, such provisions remain in force mostly for nationals of Bulgaria and Romania (no later than 2014 but 2016 for Switzerland), as well as Croatia; in the past, and to a lesser extent, such provisions also affected Estonia, Latvia, Lithuania, Poland, the Czech Republic, Slovakia, Hungary and Slovenia.
• The Commonwealth of Nations has a Commonwealth citizenship for the citizens of its members. Some member states (such as the United Kingdom) allow non-nationals who are Commonwealth citizens to vote and stand for election while resident there. Others make little or no distinction between citizens of other Commonwealth nations and citizens of non-Commonwealth nations.
• Commonwealth of Independent States nations (the republics of the former Soviet Union) are often eligible for fast track processing to citizenships of other CIS countries, with varying degrees of recognition/tolerance of dual citizenship among the states.

Potential issues

National cohesiveness

Some have questioned whether allowing dual citizenship impedes cultural assimilation, increases disconnection from the political process, and degrades national identity/cohesiveness.

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 and nullifies the consequential, transformational, and psychological change that occurs in an individual when they go through the naturalization process.

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. 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.

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:

• 32% less likely to be fluent in English
• 18% less likely to identify as "American"
• 19% less likely to consider the US as their homeland
• 18% less likely to express high levels of civic duty
• 9% less likely to register to vote
• 15% less likely to have ever voted in a national election

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).

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 United States is a "civic" nation and not an "ethnic" nation. American citizenship is not based on belonging to a particular ethnicity, but on political loyalty to American democracy and values. Regimes based on ethnicity, which support the doctrine of perpetual allegiance as one is always a member of the ethnic nation, are not concerned with assimilating non-ethnics since they can never become true citizens. In contrast, the essence of a civic nation makes it imperative that immigrants assimilate into the greater whole as there is not an "ethnic" cohesiveness uniting the populace.
• The United States is an immigrant nation. It has prospered due to its immigration policy of taking in and absorbing a very diverse stock of immigrants. As immigration is primarily directed at family reunification and/or refugee status rather than education and job skills, the pool of candidates tends to be poorer, less educated, and consistently from less stable countries (either non-democracies or fragile ones) with less familiarity or understanding of American values, making their assimilation more difficult and important.

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

• The differential exclusionary model, which accepts immigrants as temporary "guestworkers" but is highly restrictive with regard to other forms of immigration and to naturalisation of immigrants. Japan, China, Taiwan, and the countries of the Middle East tend to follow this approach.
• The assimilationist model, which accepts that immigrants obtain citizenship, but on the condition that they give up some or all cultural, linguistic, or social characteristics that differ from those of the majority population. The United States is the primary example of this model and given its massive immigration tradition and increasingly diverse population, is very sensitive to matters regarding integration (see Immigration to the United States).
• The multicultural model, which grants immigrants access to citizenship and to equal rights without demanding that they give up cultural, linguistic, and/or intermarriage restrictions or otherwise pressure them to integrate or inter-mix with the mainstream population. Canada, Australia, and many countries in Europe have historically taken this approach, but there is some evidence that Europe is moving toward the assimilationist model (see Immigration to Europe).

Appearance of foreign allegiance

Template:Globalize/US 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. However, taking advantage of the entitlements of a non-US citizenship can cause problems. For example, possession and/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".

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.

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.

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.

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. In 1999, the U.S. 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" did not bar it from employing dual citizens.

In Germany, politicians can apparently have dual citizenship with other EU countries or Switzerland. 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. Non-EU/non-Swiss dual citizenship is not allowed, so, for example, Alliance '90/The Greens politician Çem Özdemir, son of Turkish immigrants, holds only German 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 of the French civil code allows the French government to withdraw the French nationality from French citizens holding government or military positions in other countries and Jean's appointment made her both de facto 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.

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. Thomas Mulcair, Leader of the NDP and opposition leader of 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. 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 their non-Australian citizenship. However, if that other citizenship cannot be reasonably revoked, such as it being impossible under the laws of the other country or practically impossible as requiring an extremely difficult revocation process, then that person will not be disqualified from sitting in Parliament. (This restriction does not apply to members of the state parliaments, where 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. While New Zealand's Electoral Act allowed candidates with dual citizenship to be elected as MPs, Section 55 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", was passed by a majority of 61 votes to 56. 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.

Both the current 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 U.S. 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.

Taxation

Main article: International taxation

In some cases, multiple citizenship can create additional tax liability. Most countries that impose tax normally base tax liability on source and/or residency. Only two countries tax their non-resident citizens on foreign income: the United States and Eritrea.

• Residency: a country may tax the income of anyone who lives there, regardless of citizenship or whether the income was earned in that country or abroad (most common system);
• Source: a country may tax any income generated there, regardless of whether the earner is a citizen, resident, or non-resident; or
• Citizenship: a country may tax the worldwide income of its citizens, regardless of whether they reside in that country or whether the income was sourced there (as of 2012: only the United States and Eritrea). A few other countries tax based on citizenship in limited situations: Finland, France, Hungary, Italy, and Spain.

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

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 of those citizenships.

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. 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 the 15th of June.

"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, Mexico, 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 U.S. citizens, including dual nationals, must use a U.S. passport to enter and leave the United States. Also, 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 by using of 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.

See also

• Canadians of convenience
• History of citizenship
• Immigration
• Nationality
• Nationality law
• Naturalization
• Talbot v. Janson
• Tănase v. Moldova
• Third Culture Kid

References

• Spanish Civil Code (PDF), Ministry of Justice of Spain

Further reading

• Randall Hansen, Patrick Weil, ed. (2002). Dual Nationality, Social Rights and Federal Citizenship in the U. S. and Europe: The Reinvention of Citizenship. Berghahn Books. ISBN 1-57181-804-9. {{cite book}}: Unknown parameter |month= ignored (help)
• Thomas Faist, ed. (2007). Dual Citizenship in Europe: From Nationhood to Societal Integration. Aldershot, UK: Ashgate. ISBN 978-0-7546-4914-4. {{cite book}}: Unknown parameter |month= ignored (help)
• Thomas Faist, Peter Kivisto, ed. (2007). Dual Citizenship in Global Perspective: From Unitary to Multiple Citizenship. Houndmills, UK: Palgrave Macmillan. ISBN 978-0-230-00654-6. {{cite book}}: Unknown parameter |month= ignored (help)
• Thomas Faist and Jürgen Gerdes (2008). "Dual Citizenship in an Age of Mobility" (PDF). Transatlantic Council on Migration (MPI). Retrieved 2012-04-26.
• Federal Investigative Services Division of the U.S. Office of Personnel Management (2001). "Citizenship Laws of the World: A Directory" (PDF). Retrieved 2008-01-28.

External links

International

• The Hague 1930 Convention
• Convention n°8 on the exchange of information concerning acquisition of nationality, 1964

Council of Europe

• Convention on the Reduction of Cases of Multiple Nationality and on Military Obligations in Cases of Multiple Nationality, 1963
• European Convention on Nationality, 1997