What Does Dual Citizenship Mean?
Dual citizenship, or multiple citizenship in some cases, means legally being a citizen of two or more countries at the same time. There are countries that allow dual citizenship, while others do not.
A person with dual citizenship is called a dual national or bipatride. They are generally entitled to the rights of each country, such as right to a passport and right to vote. Additionally, they may also be obliged to take responsibilities of a citizen of the countries, such as national service or taxation.
Having a second citizenship is not always the same as being a dual national. To be a dual national, there must be bilateral agreements between the countries. In other words, both countries are on the same page to recognize the rights and obligations of the bipatride in each country at the official level. Without agreement, each country regards the person only as its own citizen.
According to Immigrant Invest, there are 130 countries that allow dual citizenship as of today. The infographic above marks the 130 countries and regions where you are legally allowed to have dual citizenship. Below, let’s have a glance at these countries in each region (based on The United Nations geoscheme).
Most of the African countries recognize multiple citizenship (33 out of 54 countries). These countries include Algeria, Angola, Benin, Burkina Faso, Burundi, Cape Verde, Central African Republic, and many more. Some countries such as Egypt and Morocco allow dual citizenship only when authorization is given by the government.
South Sudan, one of the youngest countries in the world, also recognizes dual citizenship. The country achieved independence from Sudan in 2011. Due to this history, Sudan automatically revokes the Sudanese citizenship if a person acquires the South Sudanese citizenship.
32 out of 57 countries in the Americas allow dual citizenship. These countries include: the US, Canada, Argentina, Brazil, Chile, Colombia, and many others including some Caribbean countries such as Barbados, British Virgin Islands, and Dominica.
Many of the countries in the region adopt jus soli, known as birthright citizenship or the right of anyone born in the territory of a state to nationality or citizenship.
Unlike the other regions, most of the countries in Asia do not recognize dual citizenship. There are 22 countries that do so: Cambodia, South Korea, Thailand, Pakistan, Sri Lanka, Russia, and others.
Some big economies in the region such as China, Japan, Singapore, and India do not recognize dual citizenship. Additionally, Hong Kong has been phasing out from dual citizenship since 2021 due to its policy shift.
A vast majority of the European countries allow dual citizenship. While most of the EU members recognize it, the Netherlands, Austria, Norway, and some others do not allow dual citizenship. Microstates such as Andorra and Monaco also do not recognize it.
There are 8 countries that allow dual citizenship in the Oceania region. They are: American Samoa, Australia, Fiji, Nauru, New Zealand, Papua New Guinea, Samoa, and Tonga.
Australia was one of the pioneering countries that actively allowed dual citizenship. On 4th April 2002, the country changed its legislation on dual citizenship, making it permissible for Australian citizens to acquire citizenship of other countries without losing their Australian citizenship.
Conditions May Apply for Dual Nationals
Some countries allow dual citizenship only with conditions. These conditions vary between countries; some are quite lenient while others are not. Switzerland and Australia have been actively moving towards permitting multiple citizenship in recent years. Some countries restrict the rights of dual nationals; for instance, a dual national cannot serve in their armed forces. Interestingly, there are some that do not allow renunciation of citizenship or voluntary loss of citizenship.
There is no single criteria for citizenship and countries exclusively define citizenship status by their national laws, which can make understanding immigration laws confronting. While dual citizenship can expand one’s opportunities in terms of career, travelling, and many others, it can also entail serious legal consequences.
The following section discusses some conditions that one may face when becoming a bipatride.
Dual Citizenship May Be Permitted If Obtained at Birth
In some countries, dual citizenship is only allowed for persons who had obtained another citizenship by birth. Austria and the Netherlands are such examples. Germany permits dual citizenship only with EU countries and Switzerland; but it also allows dual citizenship with other countries if it is obtained at birth.
Renunciations of Citizenship May Not Be Allowed
Argentina is one of the few countries that do not allow their citizens to renounce their citizenship. In other words, Argentinean citizens cannot voluntarily give up their Argentinean citizenship. As a result, an Argentinean national may not be able to acquire another citizenship that requires renunciation of other citizenship.
Political Activities May Be Limited for Dual Nationals
Being a dual national may limit their political rights—more precisely, dual nationals may not be able to hold certain elected offices. Having multiple citizenship may cause conflict of interest especially when dealing with policies relating to their second nationality.
In Egypt, neither the president nor the prime minister, including their immediate family members, cannot be dual nationals. Additionally, dual nationals are barred from military service and police academies, and they cannot run for office in Parliament. Likewise in Australia, dual nationals cannot stand for and occupy seats in Parliament.
In Israel, dual citizens are required to renounce any other nationalities if they work for the Israeli government, or the Knesset. However, it is mandatory for dual citizens to join the Israeli Defense Force upon reaching the age of 18.
Dual US Citizens May Be Double Taxed
The US and Eritrea are the only two countries that impose income tax on citizenship. So dual citizens of these countries—although Eritrea does not recognize dual citizenship for those who are naturalized—could have a US or Eritrean tax obligation regardless of where they live.
As for the US, one is required to report their income to the US even if they earned it as a foreign citizen in a foreign country. Fortunately, the US has tax treaties with a number of countries that could offset or reduce the US taxes. However, Eritrea imposes a 2% tax on all Eritrean citizens living abroad. If one holds Eritrean citizenship, they are levied a 2% tax on their worldwide income.
While many countries now recognize dual citizenship, there can be certain conditions to meet before legally becoming a dual national. Being a dual citizen can expand one’s opportunities in terms of career, travelling, privilege, and benefits; meanwhile, dual citizens can be subject to tax or military service of each country. In some cases, their rights can be limited, especially in election and politics.
Dual citizenship recognition has become increasingly popular in recent years with more and more countries allowing their citizens to have another citizenship. However, political paradigm shift or international conflict can have a significant impact on a country’s dual citizenship policy. It is vitally important to consult specialists before applying for another citizenship in order to avoid serious legal consequences such as unintended loss of the original citizenship.