|Legal status of persons|
Multiple citizenship, also called dual citizenship or multiple nationality, is a person's citizenship status, in which a person is concurrently regarded as a citizen of more than one state under the laws of those states. There is no international convention which determines the nationality or citizen status of a person, which is defined exclusively by national laws, which vary and can be inconsistent with each other. Multiple citizenship arises because different countries use different, and not necessarily mutually exclusive, criteria for citizenship. Colloquial speech refers to people "holding" multiple citizenship but technically each nation makes a claim that this person be considered its national.
Some countries do not permit dual citizenship. This may be by requiring an applicant for naturalisation to renounce all existing citizenship, or by withdrawing its citizenship from someone who voluntarily acquires another citizenship, or by other devices. Some countries do not permit a renunciation of citizenship. Some countries permit a general dual citizenship while others permit dual citizenship but only of a limited number of countries.
Most countries that permit dual citizenship still may not recognize the other citizenship of its nationals within its own territory, for example in relation to entry into the country, national service, duty to vote, etc. Similarly, it may not permit consular access by another country for a person who is also its national. Some countries prohibit dual citizenship holders from serving in their military, on police forces or holding certain public offices.
- 1 History
- 2 Citizenship of multiple countries
- 2.1 Multiple citizenship avoided
- 2.2 Involuntary multiple citizenship
- 2.3 Complex laws on dual citizenship
- 2.4 EU, ETA and EFTA countries
- 2.5 Partial citizenship
- 2.6 Multiple citizenship "not recognized"
- 2.7 "Dormant" citizenship and "right of return"
- 2.8 Multiple citizenship encouraged
- 3 Dual citizenship by region
- 4 Effects of multiple citizenship
- 5 Subnational citizenship
- 6 Supra-national citizenship
- 7 Potential issues
- 8 See also
- 9 References
- 10 Further reading
- 11 External links
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.
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. 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.
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.
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.
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. 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.
Citizenship of multiple countries
The rights of citizenship are determined by each country, which sets its own criteria for citizenship. These laws may create situations where a person may satisfy the citizenship requirements of more than one country simultaneously. This would, in the absence of laws of one country or the other, allow the person to hold multiple citizenship. National laws may include criteria as to the circumstances, if any, in which a person may concurrently hold another citizenship. A country may withdraw its own citizenship if a person acquires a citizenship of another country, for example:
- Citizenship by descent (jus sanguinis). Historically, citizenship was traced through the father, but today most countries permit the tracing through either parent, and some also through a grandparent. Today, the citizenship laws of most countries are based on jus sanguinis. In many cases, this basis for citizenship also extends to children born outside the country, and sometimes even when the parent has lost citizenship.
- 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 countries for example 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.[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). 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 adoption. A minor adopted from another country when at least one adoptive parent is a citizen.
- Citizenship by investment. Some countries give citizenship to people who make a substantial monetary investment in a country. For example, Austria, Cyprus, Dominica and St. Kitts & Nevis grant citizenship immediately, without a requirement for any presence in the country.
- Some countries grant citizenship based on religion: Israel gives all Jews the right to immigrate to Israel, by the Law of Return, and fast-tracked citizenship. Dual citizenship is permitted, but when entering the country the Israeli passport must be used. The Algerian nationality law grants citizenship only to Muslims whose father and paternal grandfather were Muslims. In the Maldives, on 7 August 2008, President Maumoon Abdul Gayoom enacted a law that allows only Muslims to become citizens of the Maldives (exceptions are persons born in the Maldives whose parents are already citizens, but the exercise of religions other than Islam is illegal).
- Citizenship by holding an office (jus oficii). In the case of Vatican City, citizenship is based on holding an office, with Vatican citizenship 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 comes to an end, and children cannot inherit it from their parents. Since Vatican citizenship is time-limited, dual citizenship is allowed, and persons who would become stateless because of loss of Vatican citizenship automatically become Italian citizens.
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", 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. 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. 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.
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.
Multiple citizenship avoided
Some countries consider multiple citizenship undesirable and take measures to avoid it. Since a country has control only over who has its citizenship, but has no control over who has any other country's citizenship, the only way for a country to avoid multiple citizenship is to deny its citizenship to people in cases when they would have another citizenship. This may take the following forms:
- Automatic loss of citizenship if another citizenship is acquired voluntarily, such as Austria, Azerbaijan, Mainland China, India, Indonesia, Japan, Kazakhstan, Nepal, 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.
- Possible (but not automatic) loss of citizenship if another citizenship is acquired voluntarily, such as 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.
Involuntary multiple citizenship
Involuntary multiple citizenship can happen in two ways:
- The parents have different citizenships or are multiple citizens themselves.[clarification needed]
- Some countries (e.g., Canada, the United States of America and most other countries in the Americas) regard all children born there automatically as citizens even if the parents are not legally present (jus soli). For example, a child born in the United States to Norwegian parents automatically has dual citizenship with the United States and Norway although 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.
Complex laws on dual citizenship
Some countries do not simply allow or forbid dual or multiple citizenship in general, but have more complex rules, such as:
- Some countries allow dual citizenship, but restrict the rights of dual citizens; in Egypt and Israel, dual citizens cannot be elected to Parliament; in Australia, dual citizens cannot be elected to the Federal parliament; in the United States, only "natural-born citizens" may hold the offices of President or Vice President, although naturalized citizens can hold any other 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. 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).
- 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. Spain has dual citizenship treaties with Argentina, Bolivia, Chile, Colombia, Costa Rica, the Dominican Republic, Ecuador, Honduras, Guatemala, Nicaragua, Paraguay, Peru, and Puerto Rico; 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. See also the section on "dormant" citizenship.
- 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 permission to keep their 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 with only 16 countries: Australia, Belgium, Canada, Egypt, France, Iceland, Ireland, Italy, Jordan, the Netherlands, New Zealand, Sweden, Switzerland, Syria, the United Kingdom, and the United States.
EU, ETA and EFTA countries
The EU and EFTA countries have various policies regarding dual citizenship, because each country can make its own laws. The only real rule is that a citizen of an EU country can live and work indefinitely in other EU countries and in the four EFTA countries (and citizens of the EFTA countries can live and work indefinitely in the EU). However, the right to vote and work in certain sensitive fields (such as government, police, military) might in some cases be restricted to the local citizens only.
The countries can exclude immigrants from getting welfare in the first three months to avoid "welfare tourism", and they can refuse welfare completely if the immigrants do not have a job after a certain period of time and do not try to get one. Immigrants convicted of welfare fraud can be deported and be refused the re-entry of the country. On September 15, 2015, the European Court of Justice ruled that EU countries can refuse to pay unemployment benefits to immigrants who have lost their job even if they are citizens of other EU countries. The judge stated that EU rules allow member states to refuse unemployment benefits to people from other EU nations to stop them becoming "an unreasonable burden on the social assistance system of the host Member State". This backs up a November 2014 ruling, in which the court ruled that "poverty immigrants" who came to Germany just to receive social security benefits were not entitled to receive them.
Within the EU, mandatory military service exists, at least in peacetime, only in Austria, Cyprus, Estonia, Finland, and Greece (In all countries but Cyprus, alternative service is available). Within the EFTA countries, only Switzerland requires it (alternative service is available); Iceland and Liechtenstein have no armed forces; in Norway, military service is de jure mandatory, but the enforcement is limited, so some sources claim it is de facto voluntary.
In Liechtenstein and in the Swiss Canton of Schaffhausen, voting is compulsory for citizens.
In the European Union, voting is mandatory for national citizens in:
- 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)
- 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)
The four microstates (Andorra, Monaco, San Marino, and Vatican City) are not EU or EFTA members. Between them, the EU, and the EFTA there is visa-free travel, but no agreements on immigration and access to the job markets.
- Austria - (see above) dual citizenship is possible with special permission or if it was obtained at birth.
- Belgium - allows dual citizenship.
- Bulgaria - Bulgarian citizens of descent can have dual citizenship, but foreigners wanting to naturalize must renounce their old citizenship.
- Croatia - generally allows citizens by descent to have dual citizenship and forbids it only in certain cases, but foreigners wanting to naturalize must renounce their old citizenship.
- Cyprus - allows dual citizenship.
- Northern Cyprus is not generally recognized by the international community as a sovereign state. No nation other than Turkey has officially recognised Northern Cyprus. The United Nations considers the declaration of independence by Northern Cyprus as legally invalid, as enunciated in several of its resolutions. The United Nations recognises Northern Cyprus as territory of the Republic of Cyprus under Turkish occupation. 
- Czech Republic - has allowed multiple citizenship since January 1, 2014.
- Denmark - allows dual citizenship since September 1, 2015. Note that not all Danish citizens are EU citizens (see below).
- Estonia - forbids dual citizenship, but citizens by descent cannot be deprived of their Estonian citizenship, so they de facto can have dual citizenship.
- Finland - allows dual citizenship.
- France - allows dual citizenship.
- Germany - (see above) allows dual citizenship with other EU countries and Switzerland; dual citizenship with other countries is possible with special permission or if obtained at birth; children of non-EU/non-Swiss legal permanent residents can have dual citizenship if born and grown up in Germany (the parents born and grown up abroad must have resided in Germany for at least eight years and must have had the legal-permanent-resident status for at least three years, and usually cannot have dual citizenship themselves).
- Greece - allows dual citizenship.
- Hungary - grants dual citizenship to people living in, and having ancestors in territories which were annexed from Hungary at the end of World War I, provided they can still speak Hungarian.
- Ireland - allows and encourages dual citizenship, but a naturalized citizen can lose Irish citizenship again when naturalizing in another country; Ireland was the last European country to abolish unconditional birthright citizenship [in 2004] in order to stop "birth tourism" and to replace it by a modified form: at least one parent must be a citizen or a legal permanent resident.
- Italy - allows dual citizenship.
- Latvia - from October 1, 2013, dual citizenship with Latvia has been allowed for citizens of member countries of EU, NATO and EFTA [Iceland, Liechtenstein, Norway, Switzerland]; citizens of Australia, Venezuela, Brazil, New Zealand; citizens of the counties that have mutual recognition of dual citizenship with Latvia; people who were granted the dual citizenship by the Cabinet of Ministers of Latvia; people who have applied for dual citizenship before the previous Latvian Citizenship law .
- 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.
- Northern Cyprus - see Cyprus, remarks about Northern Cyprus.
- Poland - does not deal with the issue of dual citizenship, but possession of another citizenship is tolerated since there are no penalties for its possession alone. However, penalties do exist for exercising foreign citizenship, such as identifying oneself to Polish authorities using a foreign identification document or serving in a foreign military without permission of Polish military authorities. Dual citizens are not exempted from their duties as Polish citizens. Under some circumstances, ethnic Poles can apply for the "Polish Card" [Karta Polaka]. (see below)
- Portugal - allows dual citizenship.
- Romania - allows dual citizenship.
- Slovakia - dual citizenship is permitted to Slovak citizens who acquire a second citizenship by birth or through marriage; and to foreign nationals who apply for Slovak citizenship and meet the requirements of the Citizenship Act. Please note that after the 'Hungarian-Slovak citizenship conflict' (year 2010) some restrictions to dual citizenship may apply.
- Slovenia - generally allows citizens by descent to have dual citizenship and forbids it only in certain cases, but foreigners wanting to naturalize must renounce their old citizenship.
- Spain - (see above) Spanish citizens by descent can have dual citizenship; Spanish laws knows a "dormant citizenship" for citizens naturalizing in Iberoamerican countries: They do not lose their citizenship, but their status and their rights as citizens of Spain—and of the EU—are inactive until they move back to Spain. Foreigners wanting to naturalize in Spain must usually renounce their old citizenship; exceptions are made for citizens of some Iberoamerican countries, Puerto Rico, Andorra, the Philippines, Equatorial Guinea, and Portugal. Since 2014, Spain has granted Spanish nationality to Sephardi Jews regardless of nationality.
- Sweden - allows dual citizenship.
- United Kingdom - allows dual citizenship. Note that not all British citizens are EU citizens (see below).
- 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.
- The Faroe Islands belong to Denmark, but not the EU, so their inhabitants are Danish citizens, but not EU citizens. Greenland left the EC in 1985, but Greenlanders are considered EU citizens.
- These British and Danish citizens obtain or procure "local" passports. In practice, citizens of Faroe Islands and Greenland can choose between local and "European" passports, and citizens of Guernsey, Jersey, and the Isle of Man receive passports bearing the title "British Islands" alongside the dependency's respective name. They can become "full" EU citizens by moving to and living permanently in the United Kingdom or in Denmark, as the case may be.
- British citizens however bearing passports from the Crown dependencies, but having sufficient connections to the UK proper, or to Gibraltar, are considered EU citizens.
- The four microstates surrounded by EU countries (Andorra, Monaco, San Marino, and Vatican City):
- These four countries are not EU or EFTA members, and only Vatican City grants (time-limited) dual citizenship (see above). Andorra, Monaco, and San Marino forbid it. In 2012, however, 78% of the 36,000 inhabitants of Monaco were foreigners and not citizens. See also Andorran nationality law and nationality law of Monaco.
- Iceland - allows dual citizenship. See also Icelandic nationality law.
- Liechtenstein - allows citizens by descent to have dual citizenship, but foreigners wanting to naturalize must renounce their old citizenship.
- Norway - allows dual citizenship only in exceptional cases. A Norwegian citizen who voluntarily acquires another citizenship automatically loses Norwegian citizenship without notification, and foreigners wanting to naturalize must usually renounce their old citizenship. For details, see Norwegian nationality law - Dual citizenship.
- Switzerland - allows dual citizenship, but the conditions for the naturalization of foreigners vary from canton to canton. Male Swiss citizens under the age of 25, including male dual citizens, are required to perform military or civilian service (women can do it voluntarily), and Swiss citizens (men and women) are not allowed to work for a foreign (non-Swiss) military. Foreign military service is a felony for Swiss citizens. (The Swiss Guards of Vatican City are regarded as a "house police", not an army.) In the Canton of Schaffhausen, voting is compulsory. For more details, see Swiss nationality law and Schweizer Bürgerrecht (in German).
The Nordic Passport Union
- The Nordic Passport Union allows citizens of Denmark (including the Faroe Islands), Sweden, Norway, Finland, and Iceland to travel and reside in other Nordic countries without a passport or a residence permit. Norway does restricts dual 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 to 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 [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.
- Many countries (e.g. USA, Canada, all EU countries and Switzerland, South Africa, Australia, New Zealand, and Singapore, amongst others) issue permanent residency status to foreigners deemed eligible. This status generally authorises one to live and work in the issuing country indefinitely, albeit 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 (and vice versa), 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 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.
"Dormant" citizenship and "right of return"
The concept of a "dormant citizenship" means that a person has the citizenships of two countries, but as long as he/she lives permanently in the one country, his/her status and citizens' rights in the other country are "inactive." They will be "reactivated" when he/she moves back to and lives permanently in the other country. This means, in spite of dual citizenship, only one citizenship can be exercised at a time.
The "dormant citizenship" exists for example in Spain: Spanish citizens who have naturalized in an Iberoamerican country and have kept their Spanish citizenship are technically dual citizens, but have lost their rights as Spanish—and EU—citizens until they move back to and live permanently in Spain. Some countries offer former citizens or citizens of former colonies of the country a simplified (re-)naturalization process. Depending on the laws of the two countries in question, dual citizenship is allowed or not. For details, see "right of return".
Multiple citizenship encouraged
Some countries are more open to multiple citizenship than others, as it may help citizens travel and conduct business overseas. Countries that have taken active steps towards permitting multiple citizenship in recent years include Switzerland (since January 1, 1992) and Australia (since April 4, 2002).
Today, most advanced economies allow dual citizenship; notable exceptions which restrict or forbid it are Austria, Germany, Japan, the Netherlands, Norway, Singapore, South Korea, and Spain. Of the newly industrialized countries, Brazil, Mexico, the Philippines, South Africa (with prior permission), Thailand, and Turkey (with prior permission) allow dual citizenship (Mexico does not allow their citizens to renounce their citizenship), while China (although Permanent Residents of Hong Kong and Macau may concurrently hold foreign passports), India, and Malaysia forbid it (but all Malaysian and some Indian citizens are Commonwealth citizens and are entitled to certain rights in the UK and other Commonwealth countries; India allows overseas citizenship – see above). Indonesia allows dual citizenship only until the age of 18 years.
In former times, some countries (Latin American countries and Canada) advertised their policy of unconditional birthright citizenship to become more attractive for immigrants. Despite wide acceptance of dual citizenship, industrialized countries now try to protect themselves from birth tourism and uncontrollable immigration waves, so only Canada and the United States still grant unconditional birthright citizenship (even for children of illegal immigrants). In both countries, there have been calls to change the laws, but, so far, they have not been successful. Brazil has similar policies; the only people born in Brazil who do not have Brazilian citizenship are the children of foreigners who abide Brazil while servicing their own country (such like diplomats, military attaché, cultural attaché and similars).
In Australia, France, Germany, Ireland, New Zealand, South Africa, and the UK, a child born there is regarded as a citizen only if at least one parent is either a citizen or a legal permanent resident who has lived there for several years. (Germany usually restricts dual citizenship, so non-EU/non-Swiss citizens born and grown up abroad must usually renounce their old citizenship when naturalizing.) Some countries (e.g. Liechtenstein) allow only citizens by descent to have dual citizenship, but require naturalized citizens to renounce their old citizenship.
Dual citizenship by region
- Some African countries restrict or forbid dual citizenship.
- It is allowed for example in Angola, Burundi, Côte d'Ivoire, Djibouti, Gabon, Gambia, Ghana, Kenya, Mali, Morocco, Mozambique, Niger, Nigeria, Rwanda, Senegal, São Tomé and Príncipe, Sierra Leone, Sudan, Tunisia, Uganda and Zambia.
- Eritreans, Egyptians, and South Africans wanting to take another citizenship need a permission to maintain their citizenship. Eritrea taxes its citizens worldwide, even if they have never lived in the country.
- Lesotho restricts dual citizenship, but observes jus soli.
- 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 2015, the fee for renunciation of U.S. citizenship was raised to $2,350 - the highest citizenship-renunciation fee worldwide.
- Dual citizenship is restricted or forbidden, for example, in Cuba, Haiti and Suriname.
- Most countries in the Asia-Pacific region restrict or forbid dual citizenship. But in some of these countries (e.g. Iran, North Korea, Thailand), it is very difficult or even impossible for citizens to renounce their citizenship, even when naturalizing in another country.
- Dual citizenship is allowed for example in Australia, Fiji, New Zealand, Philippines, Samoa, Tonga, and Vanuatu.
- Cambodia allows dual citizenship and observes jus soli for children born to legal permanent residents born in Cambodia or to children whose parents are unknown.
- South Korea allows dual citizenship in limited circumstances. It allows foreign born nationals who married to a Korean citizen, Korean men holding dual citizenship by birth who served in the Republic of Korea Armed Forces as compulsory military service, Korean women with multiple nationalities by birth who has vowed her intention not to exercise her foreign nationality in the Republic of Korea by the age of 22 and overseas Koreans at least 65 years of age.
- Taiwan and Hong Kong allow dual citizenship for citizens by birth, but do not permit applicants for naturalization to retain their prior citizenship.
- Burmese nationality law forbids its citizens to have dual citizenship, and foreigners cannot become naturalized citizens, unless they can prove a close familial connection to the country
- Pakistan restricts dual citizenship (see above), but observes jus soli.
- In Papua New Guinea there was overwhelming support from parliament to amend their Constitution to allow dual citizenship, however the law had yet to come into force as of February 2014[update].
- Sri Lanka allows dual citizenship. However, under the 19th amendment of that country's constitution, dual citizens are not allowed to hold public office.
- Israel allows dual citizenship.
- Indian constitution does not allow voluntary Dual Citizenship. However, in response to persistent demands for dual citizenship, particularly from the diaspora in North America and other developed countries, the The Overseas Citizenship of India (OCI) scheme was introduced by amending The Citizenship Act, 1955 in August 2005.
- The rest of Europe other than EU, EFTA, and microstates:
- Albania, Belarus, Moldova, Russia and Serbia allow dual citizenship. But in Russia, a second citizenship must be reported.
- Bosnia, Macedonia, and Montenegro generally do not allow dual citizenship.
- Ukrainian law currently does not recognise dual citizenship. However there are citizens of Ukraine who hold dual citizenship. This includes state officials such as Igor Kolomoisky, who holds three citizenships. On February 8, 2014, the Rada proposed a bill to criminalize the act of holding two citizenships.
Effects of multiple citizenship
It is often observed that dual citizenship may strengthen ties between migrants and their countries of origin and increase their propensity to remit funds to their communities of origin.
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. 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.
- 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 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.
- Citizens of the People's Republic of China may be permanent residents of the Hong Kong or Macau Special Administrative Regions, or have household registration (hukou) somewhere in mainland China. School enrollment, work permission, and other civic rights and privileges (such as whether one may apply for a Hong Kong SAR passport, Macau SAR passport, or People's Republic of China passport) are tied to the region in which the citizen has permanent residence or household registration. Although within mainland China the hukou system has loosened in recent years, movement between Macau, Hong Kong, and the mainland remains controlled. Mainland Chinese who migrate to Hong Kong on one-way permits have their mainland hukou cancelled, while children born in Hong Kong to visiting mainland parents cannot receive mainland hukou unless they cancel their Hong Kong permanent residence status.
- 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 regional 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.
- 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, Macedonia, Montenegro) as well as Yugoslav citizenship. In Serbia and Montenegro, this system was in effect until 2006.
- 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.
- 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.
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.
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 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 both more difficult and more 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. Many countries in Asia such as Japan, China, Taiwan, Singapore 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. Europe is the primary example of this model, where immigrants are usually required to learn the official language, and cultural traditions such as Islamic dress are often barred in public spaces (see Immigration to Europe).
- 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, 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. (See Immigration to the United States.)
Appearance of foreign allegiance
People with multiple citizenship may be viewed as having dual loyalty, having the potential to act contrary to a government's interests, and this may lead to difficulties in acquiring government employment where security clearance may be required.
In the United States, dual citizenship is associated with two categories of security concerns: foreign influence and foreign preference. Contrary to common misconceptions, dual citizenship in itself is not the major problem in obtaining or retaining security clearance in the United States. As a matter of fact, if a security clearance applicant's dual citizenship is "based solely on parents' citizenship or birth in a foreign country", that can be a mitigating condition. However, taking advantage of the entitlements of a non-US citizenship can cause problems. For example, possession or use of a foreign passport is a condition disqualifying one from security clearance and "is not mitigated by reasons of personal convenience, safety, requirements of foreign law, or the identity of the foreign country" as is explicitly clarified in a Department of Defense policy memorandum which defines a guideline requiring that "any clearance be denied or revoked unless the applicant surrenders the foreign passport or obtains official permission for its use from the appropriate agency of the United States Government".
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.
Terrorists with dual citizenship can enter some countries more easily. Especially passports of the "First World" (EU/EFTA countries, USA, Canada, Australia, New Zealand, Japan, South Korea) provide a high degree of travel freedom. Some countries have made laws to revoke the citizenship of dual citizens convicted of terrorism (e.g. Australia, Canada, The Netherlands, the United Kingdom), or are in the process of making such laws (e.g. France).[clarification needed]
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 while US Senator Ted Cruz renounced his Canadian citizenship birthright on May 14, 2014.
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" 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 Cem 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 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.
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 New Democratic Party and opposition leader of the Canadian House of Commons also holds dual citizenship with France.
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 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. (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. 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[update] 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.
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.
- 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. [clarification needed]
Only US expatriates (who have not renounced citizenship) are subject to tax on all of their worldwide income, although US law provides measures to reduce or eliminate double taxation issues for some expatriates. It has been reported that some US expatriates have renounced US citizenship in order to avoid this tax burden.
A person with multiple citizenship may have a tax liability to his country of residence and also to one or more of his countries of citizenship; or worse, if unaware that one of his citizenships created a tax liability, that country may consider the person to be a tax evader. Many countries and territories have contracted tax treaties or agreements for avoiding double taxation. Still, there are cases in which a person with multiple citizenship will owe tax solely on the basis of holding one such citizenship.[clarification needed]
For example, consider a person who holds both Australian and United States citizenship, lives and works in Australia. He would be subject to Australian taxation, because Australia taxes its residents, and he would be subject to US taxation because he holds US citizenship. In general, he would be allowed to subtract the Australian income tax he paid from the US tax that would be due. Plus, the US will allow some parts of foreign income to be exempt from taxation; for instance, in 2006 the foreign earned income exclusion allowed up to US$82,400 of foreign salaried income to be exempt from income tax (in 2014, this has now increased to US$97,600). This exemption, plus the credit for foreign taxes paid mentioned above, often results in no US taxes being owed, although a US tax return would still have to be filed. In instances where the Australian tax was less than the US tax, and if there was income that could not be exempted from US tax, the US would expect any tax due to be paid.
The United States Internal Revenue Service has excluded some regulations such as Alternative Minimum Tax (AMT) from tax treaties that protect double taxation. In its current format even if US citizens are paying income taxes at a rate of 56%, far above the maximum US marginal tax rate, the citizen can be subject to US taxes because the calculation of the Alternative Minimum Tax does not allow full deduction for taxes paid to a foreign country. Other regulations such as the post date of foreign mailed tax returns are not recognized and can result in penalties for late filing if they arrive at the IRS later than the filing date. However, the filing date for overseas citizens has a two-month automatic extension to June 15.
"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 US citizens, including dual nationals, must use a US passport to enter and leave the United States. 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.
- Canadians of convenience
- History of citizenship
- Nationality law
- Talbot v. Janson
- Tănase v. Moldova
- Third Culture Kid
- World citizenship
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L'intéressé sera, par décret en Conseil d'Etat, déclaré avoir perdu la nationalité française si, dans le délai fixé par l'injonction, délai qui ne peut être inférieur à quinze jours et supérieur à deux mois, il n'a pas mis fin à son activité.
Lorsque l'avis du Conseil d'Etat est défavorable, la mesure prévue à l'alinéa précédent ne peut être prise que par décret en conseil des ministres.
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