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Multiple citizenship

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

1 Citizenship of multiple countries

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1.1 Multiple citizenship avoided 1.2 Complex laws on dual citizenship

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1.2.1 The dual-citizenship policies of the EU and EFTA countries

1.3 "Partial" citizenship 1.4 Multiple citizenship "not recognized" 1.5 "Dormant" citizenship and "right of return" 1.6 Multiple citizenship encouraged 1.7 Multiple citizenship required

2 Dual citizenship by region 3 Subnational citizenship

3.1 Former

4 Supra-national citizenship 5 Potential issues

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5.1 National cohesiveness 5.2 Appearance of foreign allegiance

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5.2.1 Multiple citizenship among politicians

5.3 Taxation 5.4 Issues with international travel

6 See also 7 References 8 Further reading 9 External links

Citizenship of multiple countries[edit]

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

At least one parent is a citizen (jus sanguinis). Today, the citizenship laws of most countries in the world are based on jus sanguinis.

The person was born on the country's territory (jus soli). Of the advanced economies, only Canada and the United States of America grant unconditional birthright citizenship, other countries have abolished it to stop "birth tourism." Australia, France, Germany, Ireland, New Zealand, South Africa, and the United Kingdom have a modified jus soli (at least one parent must be a citizen or a legal permanent resident who has lived in the country for several years). Many Latin American countries still grant unconditional birthright citizenship.

The person marries a citizen (jure matrimonii).[1] Today, being married to a citizen of a country may shorten the time to naturalization, but only in a few countries is the new citizenship granted on the wedding day (e.g. Iran).

The person becomes naturalized. The person was adopted from another country as a minor and at least one adoptive parent is a citizen.[2] The person makes a substantial monetary investment: Austria, Cyprus, Dominica and St. Kitts & Nevis.[3] Some countries grant citizenship based on religion: In Israel, the Law of Return defines that all Jews possessing an Oleh's certificate shall become Israel nationals and be allowed to immigrate to Israel. Such a certificate would almost automatically turn into Israeli citizenship upon arrival in Israel if so desired. In the 1970s the Law of Return was further expanded, and it was defined that the spouse of a Jew, the children of a Jew and their spouses, and the grandchildren of a Jew and their spouses would also be covered under the Law of Return and thus be eligible for an Oleh's certificate provided that the Jew on behalf of whom they request the certificate did not practice a religion other than Judaism willingly (he or she may, however, be a non-observant Jew). The Algerian nationality law, promulgated in 1963, granted citizenship only to Muslims, requiring that only those individuals whose fathers and paternal grandfathers had Muslim personal status could become citizens of the new state.

In one case, citizenship is based on holding an office (jus oficii): Vatican citizenship is held by the Pope, cardinals residing in Vatican City, active members of the Holy See's diplomatic service, and other directors of Vatican offices and services. Vatican citizenship is lost when the office term is over, and children cannot

inherit it from their parents. Since Vatican citizenship is time-limited, dual citizenship is allowed (Swiss Guards even must have dual citizenship with Switzerland), and persons who would be stateless after losing Vatican citizenship automatically become Italian citizens. Since March 1, 2011, a new law has allowed permanent residency in Vatican City. Once a country bestows citizenship, it may or may not consider a voluntary renunciation of that citizenship to be valid. In the case of naturalization, some countries require applicants for naturalization to renounce their former citizenship. However, this renunciation may not be considered valid under the laws of the renounced country. Effectively, the person in question may still possess both citizenships, nonwithstanding the technical fact that he or she may have explicitly renounced one of the country's citizenships before officials of the other. For example, United States Chief Justice John Rutledge ruled "a man may, at the same time, enjoy the rights of citizenship under two governments,"[4] but the US requires applicants for naturalization to swear to an oath renouncing all prior "allegiance and fidelity" to any other nation or sovereignty as part of the naturalization ceremony.[5] In the case of a British citizen, however, the UK honors renunciation of citizenship only if done with competent UK authorities.[6] Consequently, British citizens naturalized in the US remain British citizens in the eyes of the British government even after they renounce British allegiance to the satisfaction of U.S. authorities. The Republic of Ireland applies its nationality law to "the island of Ireland", thereby extending them to Northern Ireland, which is part of the United Kingdom. Therefore, anyone born in Northern Ireland who meets the requirements for being an Irish citizen through birth on the island of Ireland (or a child born outside of Ireland but with a qualifying parent) is authorised to excercise rights accorded only to Irish citizens, including that of travelling 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 British citizens on the same basis as people born elsewhere in the United Kingdom. People born in Northern Ireland may choose to hold a British passport, an Irish passport, or both.

Multiple citizenship avoided[edit]

Some countries consider multiple citizenship undesirable and take measures to avoid it. Since a country only has control over who has its citizenship, but has no control over who has any other country's citizenship, the only way for a country to avoid multiple citizenship is to deny its citizenship to people in cases when they would have another citizenship. This may take the following forms:

Automatic loss of citizenship if another citizenship is acquired voluntarily (such as Azerbaijan,[7] Mainland China, Czech Republic, Denmark, India, Indonesia,[8] Japan,[9]Kazakhstan,[citation needed] Nepal,[citation needed] the Netherlands, Norway). In the case of the Czech Republic, two specific exceptions apply: those who acquired other citizenship after being illegally deprived of citizenship by the Communist regime of 1948

1990, or whose Slovak citizenship as of September 31, 1992, caused automatic loss of Czech citizenship upon the partition of Czechoslovakia, may apply for restoration of Czech citizenship without losing another. However, in October 2012 the Czech Ministry of the Interior presented a draft[10] of a revision of the Citizenship Act that, if passed by the Parliament, will inter alia (besides the existing options: by birth, through marriage, by means of restoration of one's citizenship in certain cases and by virtue of a statutory exception granted by the state authorities[11]) provide a new cause of obtaining dual citizenship on the basis of a voluntary acceptance of a foreign citizenship while retaining the Czech one. Thus, the Czech Republic would become one of those few EU member states (for example United Kingdom or Hungary) fully supporting dual citizenship regime.Saudi Arabian citizenship may be withdrawn if a Saudi citizen obtains a foreign citizenship without the permission of the Prime Minister.[12]

Possible (but not automatic) loss of citizenship if another citizenship is acquired voluntarily (such as Singapore, Malaysia,[citation needed] South Africa[13]).

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[14] and Montenegro. In Montenegro loss is automatic with some exceptions.)[15]

Denying automatic citizenship from birth if the child may acquire another citizenship automatically at birth. Requiring an applicant for naturalization to apply to renounce his/her existing citizenship(s), and provide proof from those countries that they have renounced citizenship, as a condition of naturalization.

Complex laws on dual citizenship[edit]

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

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

Germany and Austria for the most part do not permit dual citizenship except for persons who obtain more than one citizenship at the time of birth.[16][17] Germans and Austrians can apply for special permission to keep their citizenship (Beibehaltungsgenehmigung) before taking a second one (for example, both Austria and the U.S. consider Arnold Schwarzenegger a citizen). In general however, any Austrian who takes up a second citizenship will automatically lose Austrian citizenship. Since August 2007, Germany has 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 anymore in these cases, and in some exceptional cases, non-EU- and non-Swiss citizens can keep their old citizenship when they become citizens of Germany. For more details, see German nationality law#Dual citizenship. Changes of the German law on dual citizenship are being discussed, according to which children of non-EU legal permanent residents can have dual citizenship if born and grown up in Germany (the foreign-born parents cannot have dual citizenship themselves).

Acquisition of the nationality of Latin American countries, Andorra, the Philippines, Equatorial Guinea or Portugal is not sufficient to cause the loss of Spanish nationality by birth.[18] Spain has dual citizenship treaties with Argentina, Bolivia, Chile, Colombia, Costa Rica, the Dominican Republic, Ecuador, Honduras, Guatemala, Nicaragua, Paraguay, and Peru; Spaniards residing in these countries do not lose their rights as Spaniards if they adopt that nationality.[19][20][21] 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).[22] Upon request Spain has allowed persons from Puerto Rico to acquire Spanish citizenship.[23][24] 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 a permission to keep their citizenship, or they will lose their South African citizenship when acquiring the citizenship of another country.

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

Pakistan allows dual citizenship with 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.

The dual-citizenship policies of the EU and EFTA countries[edit]

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, voting and working in sensitive fields (government, police, military, security) are only possible in the country of citizenship. For details, see the nationality law of the country concerned and Citizenship of the European Union.

As of December 2013, the following 14 EU countries restrict or forbid dual citizenship: Austria (see above; dual citizenship is possible with special permission or if it was obtained at birth) Bulgaria (Bulgarian citizens of descent can have dual citizenship, but foreigners wanting to naturalize must renounce their old citizenship) Croatia (generally allows citizens by descent to have dual citizenship and forbids it only in certain cases, but foreigners wanting to naturalize must renounce their old citizenship) Czech Republic (forbids dual citizenship unless the non-Czech citizenship was obtained by birth or by marriage) Denmark (currently, it is a fundamental principle in the legislation to restrict dual nationality as much as possible. One exception to this is if a person is born of a Danish parent in a country that grants citizenship under the principle of jus soli; a law to allow dual citizenship is being discussed) Estonia (forbids dual citizenship, but citizens by descent cannot be deprived of their Estonian citizenship, so they de facto can have dual citizenship) Germany (see above; allows dual citizenship with other EU countries and Switzerland; dual citizenship with other countries is possible with special permission or if obtained at birth; children of non-EU legal permanent residents can have dual citizenship if born and grown up in Germany) Ireland (allows dual citizenship, but a naturalized citizen can lose Irish citizenship again when naturalizing in another country; Ireland was the last European country to abolish unconditional birthright citizenship [in 2004] in order to stop "birth tourism" and to replace it by a modified form: at least one parent must be a citizen or a permanent resident) Latvia (starting from October the 1st, 2013 dual citizenship with Latvia is allowed for citizens of member countries of EU, NATO and EFTA [Iceland, Liechtenstein, Norway, Switzerland]; citizens of Australia, Venezuela, Brazil, New Zealand; citizens of the counties that had have mutual recognition of dual citizenship with Latvia; people who were granted the dual citizenship by the Cabinet of Ministers of Latvia; people who have applied for dual citizenship before the previous Latvian Citizenship law [1995])

Lithuania (the Lithuanian Constitution states in Article 12 that only in "individual cases provided for by law" can dual citizenship be permitted. [Constitution of the Republic of Lithuania, adopted on Oct. 25, 1992, in force from Nov. 2, 1992]) Netherlands (dual citizenship is allowed under certain conditions: e.g. foreign citizenship may be kept in the event of naturalization via marriage) Spain (see above; Spanish citizens by descent can have dual citizenship; Spanish laws knows a "dormant citizenship" for citizens naturalizing in Iberoamerican countries: They do not lose their citizenship, but their status and their rights as citizens of Spainand of the EUare inactive until they move back to Spain. Foreigners wanting to naturalize in Spain must usually renounce their old citizenship; exceptions are made for citizens of some Iberoamerican countries, Puerto Rico, Andorra, the Philippines, Equatorial Guinea, and Portugal) Slovak Republic (dual citizenship is permitted to Slovak citizens who acquire a second citizenship by birth or through marriage; and to foreign nationals who apply for Slovak citizenship and meet the requirements of the Citizenship Act) Slovenia (generally allows citizens by descent to have dual citizenship and forbids it only in certain cases, but foreigners wanting to naturalize must renounce their old citizenship)

EU countries currently having no specific rules on dual citizenship:

Poland (Polish law does not deal with the issue of dual citizenship, but possession of another citizenship is tolerated since there are no penalties for its possession alone. However, penalties do exist for exercising foreign citizenship, such as identifying oneself to Polish authorities using a foreign identification document or serving in a foreign military without permission of Polish military authorities. Dual citizens are not exempted from their duties as Polish citizens. Under some circumstances, ethnic Poles can apply for the "Polish Card" [Karta Polaka], see below)

The special case of Cyprus / Northern Cyprus:

Cyprus allows dual citizenship. Northern Cyprus is not generally recognized by the international community (the EU regards the island of Cyprus as indivisible and sees Northern Cyprus as a "special region" and not as an independent country). The main country, and probably the only one, that recognizes Northern Cyprus is Turkey. Thus, a Northern Cyprus passport is not accepted as a valid travel document in most countries (exceptions: Australia, France, Syria, United Kingdom, United States, and Turkey). Citizens of Northern Cyprus are permitted to live and work in Turkey under the same requirements as

Turkish citizens. Turkey provides a special type of passport for Northern Cyprus citizens. Despite the ethnic and physical division of Turkish Cypriots from the rest of Cyprus, they can obtain Cypriot passports and ID cards if they prove to be Cypriots by descent. Turkish settlers in the northern part of Cyprus are not entitled to Cypriot citizenship.

British and Danish citizens not regarded as EU citizens:

See also: British nationality law and Danish nationality law 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 inhabitans are Danish citizens, but not EU citizens. Greenland left the EC in 1985, but Greenlanders are considered EU citizens. These British and Danish citizens get "local" passports (in practice, citizens of Faroe Islands and Greenland can choose between local and "European" passports, and citizens of the Guernsey, Jersey, and the Isle of Man receive passports bearing the title "British Isles" alongside the dependecy's respective name); they can become "full" EU citizens by moving to and living permanently in the United Kingdom or in Denmark. British citizens bearing passports from the Crown Dependencies but having sufficient connexions to the UK-proper or Gibraltar are considered EU-citizens. Greenland may in the future become an independent country. If this happens, Greenlanders will lose their Danishand EUcitizenship.

EUcandi date count ries (Mac edoni a, Mont enegr

o, Serbi a, and Turke y): Macedonia allows dual citizenship only in exceptional cases. Montenegro forbids dual citizenship, but citizens of descent cannot be deprived of their citizenship, so they de facto can have it. Serbia allows dual citizenship. Turkey allows dual citizenship, but Turkish citizens must inform the authorities before they can take a second citizenship. For former Turkish citizens, the "Blue Card" (Mavi Kart) was created, which gives them the right to live and work in Turkey (See the sections about complex laws and "partial" citizenship).

B o s n i a H e r z e g o v i n a

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

: These four countries are no EU or EFTA members, and only Vatican City grants (time-limited) dual citizenship (see above). Andorra, Monaco, and San Marino forbid it. In 2012, however, 78 % of the 36,000 inhabitants of Monaco were foreigners and not citizens.

Iceland allows dual citizenship. Liechtenstein allows citizens by descent to have dual citizenship, but foreigners wanting to naturalize must renounce their old citizenship.

Norway allows dual citizenship only in exceptional cases. A Norwegian citizen who voluntarily acquires another citizenship automatically loses Norwegian citizenship without notification, and foreigners wanting to naturalize must usually renounce their old citizenship. For details, see Norwegian nationality law - Dual citizenship. Switzerland allows dual citizenship, but the conditions for the naturalization of foreigners vary from canton to canton. Male Swiss citizens, including male dual citizens, can be required to perform military or civilian service (women can do it voluntarily), and Swiss citizens (men and women) are not allowed to work for a foreign (non-Swiss) military. (The Swiss Guards of Vatican City are regarded as a "house police" and not as an army.) In the Canton of Schaffhausen, voting is compulsory. For more details, see Swiss nationality law and Schweizer Brgerrecht (in German).

The Nordic Passport Union allows citizens of the Nordic countries of Denmark (Faroe Islands included), Sweden, Norway, Finland, and Iceland to travel and reside in other Nordic countries without a passport or a residence permit. However, Denmark and Norway restrict/forbid dual citizenship.

In 2005, India amended the 1955 Citizenship Act to introduce a form of overseas citizenship,[25] which stops just short of full dual citizenship and is, in all aspects, like permanent residency.[26] 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] if you are 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

Most African countries restrict or forbid dual citizenship. It is allowed for example in Angola, Burundi, Cte d'Ivoire, Djibouti, Gabon, Gambia, Ghana, Kenya, Mali, Morocco, Mozambique, Nigeria, Rwanda, Senegal, So Tom and Prncipe, Sierra Leone, Sudan, Tunisia, and Uganda. Eritreans, Egyptians, and South Africans wanting to take another citizenship need a permission to maintain their citizenship. Lesotho restricts dual citizenship, but observes jus soli.

Most American countries allow dual citizenship (some only for citizens by descent and / or with other American countries with which they have agreements). Some countries (e.g. Argentina, Bolivia, Brazil, Costa Rica) do not allow their citizens to renounce their citizenship, so they keep it even when naturalizing in a country that forbids dual citizenship. Most American countries observe unconditional jus soli, i.e. a baby born there is regarded as a citizen even if the parents are not. Some countries (Dominican Republic, Ecuador, Guatemala, Honduras, Mexico, Nicaragua, Uruguay) allow renunciation of citizenship only if it was involuntarily acquired by birth to non-citizen parents.

Canada and the United States of America allow dual citizenship and are worldwide the two only advanced economies to grant unconditional birthright citizenship. Dual citizenship is resticted or forbidden for example in Cuba 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.[31] 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.[32] Some territories, including Taiwan[33] and Hong Kong allow dual citizenship for citizens by birth, but do not permit applicants for naturalization to retain their prior citizenships. Israel allows dual citizenship, but most Muslim countries do not recognize Israel and reject Israeli passports and/or any passports with Israeli visa stamps. Among the Muslim countries that accept the Israeli passport are Egypt, Morocco, Tunisia, and Turkey. Pakistan restricts dual citizenship (see above), but observes jus soli.

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

Europe is divided over dual citizenship: In about half of the countries, it is allowed; in the other half, it is restricted or forbidden. For EU, EFTA, EU candidate countries (including Turkey), Bosnia-Herzegowina, Kosovo, and the European microstates, see above. 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. The rest of Europe: Albania, Armenia, Moldova, and Russia allow dual citizenship, Belarus forbids it, Georgia allows it only in exceptional cases, Ukraine accepts dual citizenship, but does not recognize it.