Multiple citizenship

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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.



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[edit]

Main articles: Citizenship and Naturalization


  • Citizenship by birth on the country's territory (jus soli). The United States, Canada, and many Latin American countries grant unconditional birthright citizenship. To stop birth tourism, most countries have abolished it; while Australia, France, Germany, Ireland, New Zealand, South Africa, and the United Kingdom have a modified jus soli, which requires at least one parent to be a citizen of the country (jus sanguinis) or a legal permanent resident who has lived in the country for several years. In the majority of such countries—for example, in Canada—children born to diplomats and under people outside the jurisdiction of the soil are not granted citizenship at birth. It is usually conferred automatically on the children once one of the parents obtain citizenship.[5][not in citation given]
  • Citizenship by marriage (jure matrimonii). Some countries routinely give citizenship to spouses of its citizens, or may shorten the time for naturalization, but only in a few countries is citizenship granted on the wedding day (e.g., Iran).[6] Some countries have regulations against so-called sham marriages (e.g., the United States), and some revoke the spouse's citizenship if the marriage terminates within a specified time (e.g., Algeria).
  • Citizenship by naturalization.
  • Citizenship by investment. Some countries give citizenship to people who make a substantial monetary investment in their country. There are three countries in Europe where this is possible and several in the Caribbean. The European countries are Malta as of 2014, Austria, and Cyprus.[8] The Caribbean countries are Antigua and Barbuda, Grenada, Dominica, St. Kitts & Nevis, and St. Lucia all grant citizenship immediately given due diligence is passed, without a requirement for any physical presence in the country.[9] In Asia, Cambodia has laws enacted that allow foreigners to obtain citizenship through investment, but is difficult to receive without fluency in Khmer.[10]

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][15] 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[edit]

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:

  • Automatic loss of citizenship if another citizenship is acquired voluntarily, such as Austria,[16] Azerbaijan,[17] People's Republic of China, India, Indonesia,[18] Japan,[19] Kazakhstan,[citation needed] Nepal,[20] the Netherlands (unless certain conditions are met), Norway. Saudi Arabian citizenship may be withdrawn if a Saudi citizen obtains a foreign citizenship without the permission of the Prime Minister.[21]
  • Possible (but not automatic) loss of citizenship if another citizenship is acquired voluntarily, such as South Africa.[22]
  • 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[23] and Montenegro. In Montenegro loss is automatic with some exceptions.[24]

Involuntary multiple citizenship[edit]

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 to be citizens (jus soli) even if the parents are not legally present. There are exceptions, such as the child of a foreign diplomat living in the United States. Such a child would be eligible to become a lawful permanent resident, but not a citizen based on the U.S. birth.[25] 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][relevant? ]

Complex laws on dual citizenship[edit]

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

  • Some countries allow dual citizenship, but restrict the rights of dual citizens:
    • in Egypt dual citizens cannot be elected to Parliament;
    • in Israel, to be sworn in as a member of Parliament, you must renounce your other citizenship before taking your seat in the Knesset;
    • in Australia, dual citizens cannot be elected to the Federal parliament;
    • in New Zealand, dual citizens may be elected to Parliament, but MPs once elected may not voluntarily become a citizen of another country, or take any act to have their foreign nationality recognised such as applying for a foreign passport. However, the only person to recently violate this, Harry Duynhoven, was protected by the passage of retroactive law;
    • in the United States, only natural-born citizens may become President or Vice President, although naturalized citizens can hold any other seat in office.
  • Germany and Austria for the most part do not permit dual citizenship except for persons who obtain more than one citizenship at the time of birth.[26][27] Germans and Austrians can apply for special permission to keep their citizenship (Beibehaltungsgenehmigung) before taking a second one (for example, both Austria and the United States 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 recognised 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 any more 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. Due to changes of the German law on dual citizenship, children of non-EU legal permanent residents can have dual citizenship if born and grown up in Germany (the foreign-born parents usually cannot have dual citizenship themselves).[citation needed]
  • Acquisition of the nationality of Andorra, Portugal, the Philippines, Equatorial Guinea or Latin American countries, is not sufficient to cause the loss of Spanish nationality by birth.[28] Spain has dual citizenship treaties with Argentina, Bolivia, Chile, Colombia, Costa Rica, the Dominican Republic, Ecuador, Honduras, Guatemala, Nicaragua, Paraguay, Peru, Puerto Rico and Venezuela; Spaniards residing in these countries do not lose their rights as Spaniards if they adopt that nationality.[29][30][31] 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).[32] Upon request Spain has allowed persons from Puerto Rico to acquire Spanish citizenship.[33][34] 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. See also the section on "dormant" citizenship.[citation needed]
  • 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.[citation needed]
  • Like Germans and Austrians, citizens of South Africa must apply for permission to keep their citizenship when acquiring the citizenship of another country.[35]

EU and EFTA countries[edit]


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.[36]

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.[citation needed]

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:

  • Belgium (compulsory for all citizens from age 18 to present themselves at a polling station; legal sanctions exist, but only the sanctions for absent appointed polling station staff have been enforced by prosecutors since 2003)
  • Cyprus
  • Luxembourg (compulsory for national citizens between the age of 18 and 75; voluntary for those over the age of 75 and for residing foreigners in local and EU elections only)


EU countries[edit]

For details, see the nationality law of the country concerned and Citizenship of the European Union.[37]

Belgium - allows dual 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.[38] The United Nations considers the declaration of independence by Northern Cyprus as legally invalid, as enunciated in several of its resolutions.[39][40] The United Nations recognises Northern Cyprus as territory of the Republic of Cyprus under Turkish occupation.[39] 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.[citation needed]
Czech Republic - has allowed multiple citizenship since January 1, 2014.[41]
Denmark - allows dual citizenship since September 1, 2015. Note that not all Danish citizens are EU citizens (see below).
Finland - allows dual citizenship.
France - allows dual citizenship.
Greece - allows dual citizenship.
Hungary - allows dual citizenship; 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.
Italy - allows dual citizenship.
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.
Portugal - allows dual citizenship.
Romania - allows dual citizenship.
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, so it is unclear yet what the result will be.
  • British and Danish citizens not regarded as EU citizens:
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.
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.

EFTA countries[edit]

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.

The Nordic Passport Union[edit]

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.[citation needed]

Partial citizenship[edit]


In 2005, India amended the 1955 Citizenship Act to introduce a form of overseas citizenship,[44] which stops just short of full dual citizenship and is, in all aspects, like permanent residency.[45] 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 [clarification needed] 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"[edit]

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.[47]




Multiple citizenship encouraged[edit]

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).[49][50]

Today, most advanced economies allow dual citizenship;[51] 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.[citation needed]

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 automatically acquire Brazilian citizenship are those whose parents are residing in Brazil while serving their own countries (as diplomats, military attachés, cultural attachés and the like).[citation needed]

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.[citation needed]

Dual citizenship by region[edit]

  • Africa:
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[22] 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.[citation needed]
Lesotho restricts dual citizenship, but observes jus soli.
  • The Americas:
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.[52][53]
Dual citizenship is restricted or forbidden, for example, in Cuba, Haiti and Suriname.
  • Asia-Pacific:
Taiwan[56] 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
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.[57]
Sri Lanka allows dual citizenship.[58] 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.[59] 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.[60]
  • The rest of Europe other than EU, EFTA, and microstates:
Albania,[citation needed] Belarus,[citation needed] Moldova,[61] Russia[62] and Serbia[63] allow dual citizenship. But in Russia, a second citizenship must be reported.
Bosnia,[citation needed] Macedonia,[citation needed] and Montenegro[citation needed] 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.[64]

Effects of multiple citizenship[edit]

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.[65]

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.[66] 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.[67]

Subnational citizenship[edit]

  • In Bosnia and Herzegovina, citizens hold also citizenship of their respective entity, generally that in which they reside. This citizenship can be of the Republika Srpska or of the Federation of Bosnia and Herzegovina. One cannot hold both entity citizenships simultaneously.[citation needed]
  • In Malaysia, a federation of thirteen states, each state gives certain benefits such as baby bonus, education loans and scholarships to children born in the state (or born to parents who were born in the state) and/or residing in the state. The states of Sabah and Sarawak in East Malaysia each has its own immigration control and permanent residency system; citizens from Peninsular Malaysian states are subject to immigration control in the two states.


Supra-national citizenship[edit]

  • 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, and in highly limited circumstances, may deport or refuse entry to citizens of other EU states. 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 Croatia (no later than 2020); in the past, and to a lesser extent, such provisions also affected Estonia, Latvia, Lithuania, Poland, the Czech Republic, Slovakia, Hungary, Slovenia, Bulgaria and Romania.
  • The United Kingdom recognises a Commonwealth citizenship for the citizens of the member states of the Commonwealth of Nations. The United Kingdom allow non-nationals who are Commonwealth citizens to vote and stand for election while resident there, while most other Commonwealth countries make little or no distinction between citizens of other Commonwealth nations and citizens of non-Commonwealth nations.

Potential issues[edit]

National cohesiveness[edit]

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.[75]




  • 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



  • The United States is an immigrant nation. As immigration is primarily directed at family reunification and refugee status rather than education and job skills, the pool of candidates tends to be poorer, less educated,[82] and consistently from less stable countries (either non-democracies or fragile ones) with less familiarity or understanding of American values, making their assimilation both more difficult and more important.[81]


  • 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. Many countries in Asia such as Japan, China, Taiwan, Singapore and the countries of the Middle East tend to follow this approach.
  • The multicultural model, which grants immigrants access to citizenship and to equal rights without demanding that they give up cultural, linguistic, or intermarriage restrictions or otherwise pressure them to integrate or inter-mix with the mainstream population. Canada, Australia, New Zealand and the United States have historically taken this approach, as exemplified by the fact that the United States has no official language, allowing official documents such as election ballots to be printed in a variety of languages.[85] (See Immigration to the United States.)

Appearance of foreign allegiance[edit]



This guideline has been followed in administrative rulings[88] by the United States Department of Defense (DoD) Defense Office of Hearings and Appeals[89] (DOHA) office of Industrial Security Clearance Review[90] (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.[91]



Multiple citizenship among politicians[edit]

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[94] while US Senator Ted Cruz renounced his Canadian citizenship birthright on May 14, 2014.[95][96]

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"[97] did not bar it from employing dual citizens.[98]

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[99] 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.[100]

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.[101] 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.[citation needed]

The Constitution of Australia, in Section 44(i), explicitly forbids people who hold foreign citizenship from sitting in the parliament of Australia.[102] 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.[103] (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.[104] While New Zealand's Electoral Act allowed candidates with dual citizenship to be elected as MPs, Section 55[105] 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",[106] was passed by a majority of 61 votes to 56.[107] 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.[108]

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.[109]


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.[110]

  • 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).[citation needed] A few other countries tax based on citizenship in limited situations: Finland[citation needed], France[citation needed], Hungary[citation needed], Italy,[citation needed] and Spain.[citation needed] [clarification needed]






Issues with international travel[edit]


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.[117] 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.[citation needed]

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.[118]

See also[edit]


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Further reading[edit]

External links[edit]

Council of Europe