Dual Citizenship

Defining Dual Citizenship

Dr. Jean-Philippe Chetcuti | 13 Apr 2017

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Dual citizenship arises when a person holds two or more citizenships simultaneously. Every country is sovereign in enacting the laws regulating citizenship and the conditions under which a person is granted, renounces or loses citizenship is strictly within the discretion of every state.

People holding Dual Citizenship can exercise the rights conferred to them at law in those countries in which they hold citizenship. Citizens acquiring dual citizenship would in general be required to show that there is some form of genuine link with the country issuing the citizenship.

For a long time many countries considered dual citizenship as problematic and something that should be avoided for any of its citizens. However in recent years many countries have adopted a more favourable stance towards allowing their citizens to hold Dual Citizenship through relaxation of requirements for naturalisation or simply through allowing or recognising Dual/Multiple Citizenship without the need to renounce their original citizenship.

Attaining Dual Citizenship

There are various reasons and instances under which a person may hold dual or multiple citizenship. The most common reasons for dual citizenship are:

  • Marriage to a citizen of another country
  • Adoption by parents who are citizens of another country
  • Birth in a country that grants citizenship by birth (ius soli), to parents who are citizens of a country that grants citizenship by descent (ius sanguinis)
  • Granting of citizenship by naturalisation following the successful application to citizenship by investment programmes (ius pecuniae).

In all cases the timeframe and process for naturalisation varies according to the situation and the country granting the citizenship.

Over the past years numerous countries have developed citizenship by investment programmes to attract High Net Worth Individuals and Foreign direct Investment. Through these programmes investors are granted the right to reside in another state and acquire citizenship subject to a minimal residency requirement and other investment criteria as is the case in the Malta citizenship by investment programme. Other countries offer citizenship solely based on investment criteria without the need of residence such as with the Cyprus citizenship by investment programme and Caribbean programmes

Benefits of Dual Citizenship

In today’s globalised world, obtaining a second citizenship can provide numerous benefits to different categories of people.

For the high net worth business person a second citizenship means freedom to travel without going through the bureaucracy of getting visa permits, especially in cases where the passport they hold does not give the comfort of visa free travel to a large number of countries.  Attaining a second citizenship could also mean better investment and business opportunities which would otherwise be difficult to conclude based on the original passport.

For many high net worth families attaining Dual Citizenship means the unlocking of their full potential by seeking better opportunities in another country, or simply ensuring the security of their family. A second citizenship opens new opportunities for families seeking better education and work opportunities for their children. Others see the benefits of accessing better healthcare facilities for elderly or sick dependents. Wealthy families can also seek to attain Dual Citizenship to ensure better wealth management in countries which offer advantageous tax planning options.  For families coming from countries which are passing through a period of war or political unrest, a second citizenship offers a gateway to security in another country. 

Others can see Dual citizenship as a means to enjoy freedom to travel to discover the world, experience new cultures and people, or to simply enjoy a better lifestyle in a country away from the country of birth.

Laws regulating Dual Citizenship

Whilst today the majority of countries have adopted rules allowing for Dual Citizenship there are still a number of countries that do not allow their citizens to hold Dual Citizenship, or impose a number of restrictions upon the holding of such. Consequently, it is prudent to seek legal advice on the laws governing the status of Dual Citizenship in your country prior to starting the process of seeking a second citizenship. 

Based on our research*, below is a selection of countries that allow, restrict or pose conditions with respect to Dual Citizenship.

Countries allowing Dual Citizenship

Argentina Antigua Australia Belgium
Brazil Canada Cyprus Czech Republic
Denmark Dominica Finland France
Ghana Greece Grenada Hungary
Iraq Ireland Israel Italy
Jordan Kenya Lebanon Lativa
Libya Luxemburg Malta Mexico
Morocco New Zealand Philippines Portugal
Romania Russia St. Kitts & Nevis St Lucia
Sudan Sweden  Switzerland Syria
Tunisia Turkey Uruguay UK
USA Zambia    

Countries restricting Dual Citizenship

Andorra Azerbaijan Bahrain Belarus
Brunei China Cuba Estonia
India Indonesia Japan Kazakhstan
Kuwait Kyrgyzstan Malaysai Monaco
Myanmar Mongolia Nepal Oman
Papua New Guinea Qatar Saudi Arabia Singapore
Tajikistan Thailand Ukraine Uzbekistan
United Arab Emirates Yemen     

Countries allowing Dual Citizenship under certain conditions only

Austria Bosnia Egypt Germany
Georgia Lithuania Netherlands Moldova
Norway Pakistan Slovenia South Korea
South Africa Spain    

* Due to frequent changes in laws, the above classification may be subject to changes. Whilst every effort has been made to present up to date information, the above does not constitute legal advice.


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