Multiple citizenship (or multiple nationality) is a person's legal status in which a person is at the same time recognized by more than one country under its nationality and citizenship law as a national or citizen of that country. There is no international convention that determines the nationality or citizenship status of a person, which is consequently determined exclusively under national laws, that often conflict with each other, thus allowing for multiple citizenship situations to arise.

A person holding multiple citizenship is, generally, entitled to the rights of citizenship in each country whose citizenship they are holding (such as right to a passport, right to enter the country, right to work, right to own property, right to vote, etc.) but may also be subject to obligations of citizenship (such as a potential obligation for national service, becoming subject to taxation on worldwide income, etc.).

Some countries do not permit dual citizenship or only do in certain cases (e.g., inheriting multiple nationalities at birth). This may be by requiring an applicant for naturalization to renounce all existing citizenship, by withdrawing its citizenship from someone who voluntarily acquires another citizenship, or by other devices. Some countries permit a renunciation of citizenship, while others do not. Some countries permit a general dual citizenship while others permit dual citizenship but only of a limited number of countries.

A country that allows dual citizenship may still not recognize the other citizenship of its nationals within its own territory (e.g., 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 armed forces or on police forces or holding certain public offices.[1]


Up until the late 19th century, nations often decided whom 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 due to policies that originated with the feudal theory of perpetual allegiance to the sovereign. This meant that people could hold multiple citizenships, with none of their nations recognizing any other of their citizenships. Until the early modern era, when levels of migration were insignificant, this was not a serious issue. However, when non-trivial levels of migration began, this state of affairs sometimes led to international incidents, with countries of origin refusing to recognize the new nationalities of natives who had migrated, and, when possible, conscripting natives who had naturalized as citizens of another country into military service. The most notable example was the War of 1812, triggered by UK impressment into naval service of US sailors who were alleged to be British subjects.[2][3]

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 UK authorities considered them to be British subjects. This outraged many Irish-Americans, to which the UK responded by pointing out that, just like UK law, US law also recognized perpetual allegiance.[2] As a result, Congress passed the Expatriation Act of 1868, which granted Americans the right to freely renounce their US citizenship. The UK followed suit with a similar law and, years later, signed a treaty agreeing to treat British subjects who had become US citizens as no longer holding UK nationality. During this time, diplomatic incidents had also arisen between the US and several other European countries over their tendency to conscript naturalized US citizens visiting their former homelands. In response, the US government negotiated agreements with various European states known as the Bancroft Treaties, under which the signatories pledged to treat the voluntary naturalization of a former citizen or national with another sovereign nation as a renunciation of their citizenship.[2]

As a result, the theory of perpetual allegiance largely fell out of favor with governments during the late 19th century. With the consensus of the time being that dual citizenship would only lead to diplomatic problems, more governments began prohibiting it and revoking the nationality of citizens holding another nationality. By the mid-20th century, dual nationality was largely prohibited worldwide, although there were exceptions. For example, a series of US Supreme Court rulings permitted Americans born with citizenship in another country to keep it without losing their US citizenship.[2][4]

At the League of Nations Codification Conference, 1930, 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. The 1930 Convention on Certain Questions Relating to the Conflict of Nationality Laws proposed laws that would have reduced both but, in the end, were ratified by only 20 nations.[2]

However, the consensus against dual nationality began to erode due to changes in social mores and attitudes. By the late 20th century, it was becoming gradually accepted again.[2] Many states were lifting restrictions on dual citizenship. For example, the British Nationality Act 1948 removed restrictions on dual citizenship in the UK, the 1967 Afroyim v. Rusk ruling by the US Supreme Court prohibited the US government from stripping citizenship from Americans who had dual citizenship without their consent, and the Canadian Citizenship Act, 1976, removed restrictions on dual citizenship in Canada. The number of states allowing multiple citizenships 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.[5]

Citizenship of multiple countries

Main articles: Citizenship and Naturalization

Picture of two passport documents.
Dual citizenship means persons can have or travel with two passports

Each country sets its own criteria for citizenship and the rights of citizenship, which change from time to time, often becoming more restrictive. For example, until 1982, a person born in the UK was automatically a British citizen; this was subjected to restrictions from 1983. 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 citizenships. 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:

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, the US Chief Justice John Rutledge ruled "a man may, at the same time, enjoy the rights of citizenship under two governments",[12] 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.[13] However, some countries do not recognise one of its citizens renouncing their citizenship. Effectively, the person in question may still possess both citizenships, notwithstanding the technical fact that they may have explicitly renounced one of the country's citizenships before officials of the other. For example, the UK recognizes a renunciation of citizenship only if it is done with competent UK authorities.[14][15] Consequently, British citizens naturalized in the US remain British citizens in the eyes of the UK government even after they renounce British allegiance to the satisfaction of US authorities.[11]

Irish nationality law applied to "the island of Ireland", between 1999 and the 24 of June 2004, extended citizenship to Northern Ireland, which is part of the UK. Therefore, anyone born in Northern Ireland before 11 June 2004 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) could exercise rights accorded only to Irish citizens, including that of traveling under an Irish passport. Under previously, Irish law, even that 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 from birth on the same basis as people born elsewhere in the UK. People born in Northern Ireland may generally choose to hold a British passport, an Irish passport, or both.[11]

Multiple citizenship avoided

Some countries may take measures to avoid creation of multiple citizenship. 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 citizenship

Countries may bestow citizenship automatically (i.e., "by operation of law"), which may result in multiple citizenships, in the following situations:

Complex laws on dual citizenship

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Some countries have special rules relating to multiple citizenships, such as:

Partial citizenship, and residency

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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.

In 2005, India amended the 1955 Citizenship Act to introduce a form of overseas citizenship,[61] 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. 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 allow dual citizenship.[62]

Multiple citizenship "not recognized"

See also: Master Nationality Rule

A statement that a country "does not recognize" multiple citizenship is confusing and ambiguous. Often, it is simply a restatement of the Master Nationality Rule, whereby a country treats a person who is a citizen of both that country and another in the same way as one who is a citizen only of the country. In other words, the country "does not recognize" that the person has any other citizenship for the purposes of the country's laws. In particular, citizens of a country may not be permitted to use another country's passport or travel documents to enter or leave the country, or be entitled to consulate assistance from the other country.[65] Also, the dual national may be subject to compulsory military service in countries where they are considered to be nationals.[66]

"Dormant" citizenship and "right of return"

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The concept of a "dormant citizenship" means that a person has the citizenships of two countries, but as long as while living permanently in one country, their status and citizen's rights in the other country are "inactive". They will be "reactivated" when they move back to live 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 dual citizens, but have lost many of the rights of Spanish citizens resident in Spain—and hence the EU—until they move back to 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 may or may not be allowed. For details, see "right of return".[67]

Another example of "dormant citizenship" (or "hidden citizenship") occurs when a person is automatically born a citizen of another country without officially being recognized. In many cases, the person may even be unaware that he holds multiple citizenship. For example, due to Italy's nationality law, a person born in Canada to parents of Italian ancestry may be born with both Canadian and Italian citizenship at birth. Canadian citizenship is automatically acquired by birth within Canada. However, that same person may also acquire Italian citizenship at birth if at least one parent's lineage traces back to an Italian citizen. The person, their parent, grandparent, great-grandparent, and great-great-grandparent may have all transmitted the Italian citizenship to the next child in the line without even knowing it. Therefore, even if the person in this case may have been four generations removed from the last Italian-born (and therefore recognized) citizen, the great-great-grandparent, he would still be born with Italian citizenship. Even though the person may not even be aware of the citizenship, it doesn't change the fact that he is a citizen since birth. Therefore, the second citizenship (in this case, the Italian citizenship) is "dormant" (or "hidden") due to the fact that the person does not even know he is a citizen and/or does not have official recognition from the country's government. That person would therefore have to gather all necessary documents and present them to the Italian government so that their "dormant" or "hidden" citizenship will be recognized. Once it's recognized, he will be able to do all of the things that any citizen could do, such as apply for a passport.

Multiple citizenship encouraged

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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).[68][69]

Today, most advanced economies allow dual citizenship;[70] notable exceptions which restrict or forbid it are Austria[citation needed], Japan, the Netherlands, and Singapore. Of the newly industrialized countries, Brazil (with rare exceptions), Mexico, the Philippines (natural born citizens only),[71] South Africa (with prior permission), Thailand, and Turkey (with prior permission) allow dual citizenship, while China (although Permanent Residents of Hong Kong and Macau may concurrently hold foreign passports), India, and Malaysia forbid it. Indonesia allows dual citizenship only until the age of 18 years.[20]

In former times[timeframe?], most countries on the American continent advertised their policy of unconditional birthright citizenship to become more attractive for immigrants.[citation needed] Despite wide acceptance of dual citizenship, industrialized countries (Canada and the United States) now try to protect themselves from birth tourism and uncontrollable immigration waves. Most of these countries still[timeframe?] grant unconditional birthright citizenship (even for children of illegal immigrants). There have been some calls to change the laws, but, so far[timeframe?], they have not been successful. Brazil has such policies; the only people born in Brazil who do not automatically acquire Brazilian citizenship are those whose parents are residing in Brazil while serving their own countries (as diplomats, military attachés, cultural attachés and the like).[citation needed]

In Australia, France, Germany, Ireland, New Zealand, South Africa, and the UK, a child born there is regarded as a citizen only if at least one parent is either a citizen or a legal permanent resident who has lived there for several years. (Germany usually restricts dual citizenship, so non-EU/non-Swiss citizens born and raised abroad must usually renounce their old citizenship when naturalizing.) Some countries (e.g. Liechtenstein) allow only citizens by descent to have dual citizenship and require naturalized citizens to renounce their old citizenship.[citation needed]

Subnational citizenship

Former instances

Supra-national citizenship

Effects and potential issues

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.[84]

Qualitative research on the effect 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 reduces 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.[85]

National cohesiveness

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A study published in 2007 in The Journal of Politics explored questions of whether allowing dual citizenship impedes cultural assimilation or social integration, increases disconnection from the political process, and degrades national or civic identity/cohesiveness.[86]

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[87] and nullifies the consequential, transformational, and psychological change that occurs in an individual when they go through the naturalization process.[88]

In effect, this approach argues that 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.[89] 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.[90]

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, finding dual citizens:[91]

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).[91]

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 degree of angst over the effects of dual citizenship seemingly corresponds to a country's model for managing immigration and ethnic diversity:

Appearance of foreign allegiance

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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.[97] 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".[98]

This guideline has been followed in administrative rulings[99] by the United States Department of Defense (DoD) Defense Office of Hearings and Appeals[100] (DOHA) office of Industrial Security Clearance Review[101] (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 U.S. and Ireland, despite the fact that it has with good relations with the US.[102] 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.[103]

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.[104]

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[105] while US Senator Ted Cruz renounced his Canadian citizenship birthright on 14 May 2014.[106][107]

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"[108] did not bar it from employing dual citizens.[109]

In Germany, politicians can have dual citizenship. David McAllister, who holds British and German citizenship, was minister president of the State of Lower-Saxony from July 1, 2010, to February 19, 2013. He was the first German minister president to hold dual citizenship.

A small controversy arose in 2005 when Michaëlle Jean was appointed the Governor General of Canada (official representative of the Queen). Although Jean no longer holds citizenship in her native Haiti, her marriage to French-born filmmaker Jean-Daniel Lafond allowed her to obtain French citizenship several years before her appointment. Article 23-8[110] of the French civil code allows the French government to withdraw French nationality from French citizens holding government or military positions in other countries and Jean's appointment made her both de facto 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.[111]

However, former Canadian Prime Minister John Turner was born in the United Kingdom and still retained 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.[112] Thomas Mulcair, Leader of the New Democratic Party and former leader of Official Opposition in the Canadian House of Commons also holds dual citizenship with France.

In Egypt, dual citizens cannot be elected to Parliament.[citation needed]

The Constitution of Australia, in Section 44(i), explicitly forbids people who hold allegiance to foreign powers from sitting in the parliament of Australia.[113] 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. 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.[114] In the 2017 Australian parliamentary eligibility crisis, the High Court disqualified Australia's Deputy Prime Minister and four senators because they held dual citizenship, despite being unaware of their citizenship status when elected.

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.[115] While New Zealand's Electoral Act allowed candidates with dual citizenship to be elected as MPs, Section 55[116] 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",[117] was passed by a majority of 61 votes to 56.[118] 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.[119]

Both the former Estonian president Toomas Hendrik Ilves and the former Lithuanian president Valdas Adamkus had been naturalized US citizens prior to assuming their offices. Both have renounced their US citizenships: Ilves in 1993 and Adamkus in 1998. This was necessary because neither individual's new country permits retention of a former citizenship. Adamkus was a high-ranking official in the Environmental Protection Agency, a federal government department, during his time in the United States. Former Latvian president Vaira Vīķe-Freiberga relinquished Canadian citizenship upon taking office in 1999.[120]


Main article: International taxation

In some cases, multiple citizenship can create additional tax liability. Almost all countries that impose tax normally base tax liability on source or residency. A very small number of countries tax their non-resident citizens on foreign income; examples include the United States, Eritrea, and the Philippines[121][122]

Under Spanish tax law, Spanish nationals and companies still have tax obligations with Spain if they move to a country that is in the list of tax havens[123] and cannot justify a strong reason, besides tax evasion. They are required to be residents of that country for a minimum of 5 years; after which they are free from any tax obligations.

U.S. persons living outside the United States are still subject to tax on their worldwide income, although U.S. tax law provides measures to reduce or eliminate double taxation issues for some, namely exemption of earned income (up to an inflation-adjusted threshold which, as of 2023, is $120,000[124]), exemption of basic foreign housing,[125] as well as foreign tax credits. It has been reported that some US citizens have relinquished US citizenship in order to avoid possible taxes, the expense and complexity of compliance, or because they have been deemed unacceptable to financial institutions in the wake of FATCA.[126][127][128]

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 signed 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. For example, consider a person who holds both Australian and United States citizenship, and lives and works in Australia. He would be subject to Australian taxation, because Australia taxes its residents, and he would be subject to U.S. taxation because he holds U.S. citizenship. In general, he would be allowed to subtract the Australian income tax he paid from the U.S. tax that would be due. In addition, the U.S. will allow some parts of foreign income to be exempt from taxation; for instance, in 2018 the foreign earned income exclusion allowed up to US$103,900 of foreign salaried income to be exempt from income tax (in 2020, this was increased to US$107,600).[124] This exemption, plus the credit for foreign taxes paid mentioned above, often results in no U.S. taxes being owed, although a U.S. tax return would still have to be filed. In instances where the Australian tax was less than the U.S. tax, and where there was income that could not be exempted from U.S. tax, the U.S. 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. [citation needed] In its current format even if U.S. citizens are paying income taxes at a rate of 56%, far above the maximum U.S. marginal tax rate, the citizen can be subject to US taxes because the calculation of the AMT 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.[129]

"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)[citation needed]

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,[130] Mexico,[131] 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.[citation needed]

Multiple citizens who travel to a country of citizenship are often 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.[132] 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.[133] Individuals who possess multiple citizenships, may also be required, before leaving a country of citizenship, to fulfill requirements ordinarily required of its resident citizens, including compulsory military service or exit permits. An example of this occurs in Israel, which permits multiple citizenships whilst also requiring compulsory military service for its citizens.

In accordance with the European Travel Information and Authorisation System (ETIAS), the EU citizens who have multiple nationalities will be obliged to use the passport issued by an EU Member State for entering the Schengen area.[134]

Military service

Military service for dual nationals can be an issue of concern. Several countries have entered into a Protocol relating to Military Obligations in Certain Cases of Double Nationality established at The Hague, 12 April 1930. The protocol states "A person possessing two or more nationalities who habitually resides in one of the countries whose nationality he possesses, and who is in fact most closely connected with that country, shall be exempt from all military obligations in the other country or countries. This exemption may involve the loss of the nationality of the other country or countries." The protocol has several provisions.[135]


The right to healthcare in countries with a public health service is often discussed in relation to immigration but is a non-issue as far as nationality is concerned. The right to use public health services may be conditioned on nationality and/or on legal residency. For example, anyone legally resident and employed in the UK is entitled to use the National Health Service; non-resident British citizens visiting Britain do not have this right unless they are UK state pensioners who hold a UK S1 form.[citation needed]

Dominant and effective nationality

The potential issues that dual nationality can pose in international affairs have long been recognized, and as a result, international law recognizes the concept of "dominant and effective nationality", under which a dual national will hold only one dominant and effective nationality for the purposes of international law to one nation that holds their primary national allegiance, while any other nationalities are subordinate. The theory of dominant and effective nationality emerged as early as 1834. Customary international law and precedent have since recognized the idea of dominant and effective nationality, with the Nottebohm case providing an important shift. The International Court of Justice defines effective nationality as a "legal bond having as its basis a social fact of attachment, a genuine connection of existence, interests and sentiments, together with the existence of reciprocal rights and duties". International tribunals have adopted and used the principle. Under customary international law, tribunals dealing with questions involving dual nationality must determine the effective nationality of the dual national by determining to which nation the individual has more of a "genuine link". Unlike dual nationality, one may only be the effective national of a single nation, and different factors are taken into consideration to determine effective nationality, including habitual residence, family ties, financial and economic ties, cultural integration, participation in public life, armed forces service, and evidence of sentiment of national allegiance.[136]

Countries that do not allow renunciation of citizenship

Source: German Federal Government (as of July 2023)

Citizens of these countries may keep their old citizenship even if naturalizing in a country that forbids dual citizenship – or that country may refuse their naturalization.

Dual citizenship by region


Dual citizenship is allowed in Angola, Burundi, Comoros, Cabo Verde, Côte d'Ivoire, Djibouti, Gabon, Gambia, Ghana, Kenya, Malawi, Mali, Morocco, Mozambique, Niger, Nigeria, Rwanda, Senegal, São Tomé and Príncipe, Sierra Leone, Sudan, Tunisia, Uganda, Zambia and Zimbabwe; others restrict or forbid dual citizenship. Lesotho observes dual citizenship,[citation needed] as well as jus soli. There are problems regarding dual citizenship in Namibia.[137] Eritreans,[citation needed] Egyptians,[citation needed] and South Africans[28] wanting to take another citizenship need permission to maintain their citizenship, though multiple citizenship acquired from birth is not affected. Eritrea taxes its citizens worldwide, even if they have never lived in the country.[138] Equatorial Guinea does not allow dual citizenship, but it is allowed for children born abroad, if at least one parent is a citizen of Equatorial Guinea.[139] Tanzania and Cameroon do not allow dual citizenship.[140]

The Americas

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

Dual citizenship is restricted or forbidden in Cuba, Suriname, Panama,[141] and Guyana.

Middle East/Asia Pacific

Most countries in Asia restrict or forbid dual citizenship.[citation needed] In some of these countries (e.g. Iran, North Korea, Kuwait), it is very difficult or even impossible for citizens to renounce their citizenship, even if a citizen is naturalized in another country.[citation needed]


EU and EFTA countries and microstates

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See also: European Union citizenship

EU and EFTA countries have varying policies regarding dual citizenship. Under EU rules, a citizen of one EU or EFTA country can live and work indefinitely in the other EU and EFTA countries. However, countries can limit the right to vote and work in certain sensitive fields (such as government, police, military) to local citizens only.[165] Immigrants from another EU or EFTA country can be refused welfare benefits.[166] Welfare fraud may result in deportation. For consular protection in non-EU/non-EFTA countries, immigrants must contact the embassy of the country of their citizenship, not the one of their guest country (exception: In countries where there is no embassy of their home country, citizens of an EU country have the right to get consular protection from the embassy of any other EU country present in that country.)

Within the EU, mandatory military service exists, at least in peacetime, only in Austria, Cyprus, Estonia, Finland, and Greece (In all countries but Cyprus, alternative service is available). Within the EFTA countries, only Switzerland requires it (alternative service is available); Iceland and Liechtenstein have no armed forces; in Norway, military service is de jure mandatory, but the enforcement is limited, so some sources claim it is de facto voluntary.[citation needed]

EU countries and microstates

For details, see the nationality law of the country concerned and Citizenship of the European Union.[167]

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. In practice, citizens of Faroe Islands and Greenland can choose between local and "European" passports and can become "full" EU citizens by moving to and living permanently in Denmark. (See also Danish nationality law)
Nationals of Nordic countries (Denmark, Finland, Iceland, Norway and Sweden) are free to enter, reside and work in the Faroe Islands and Greenland; citizens of other EU/EFTA countries can visit them visa-free for 90 days.
EU/EFTA citizens can enter and reside for an unlimited period without a visa in Overseas France. They may use their national identity card instead of their passport as a travel document to enter any French territory. They may also work freely in the parts of Overseas France that are part of the European Union (overseas departments and regions, and Saint Martin), but those who are not nationals of France need a permit to work in other parts such as French Polynesia, New Caledonia, and Wallis and Futuna.
Although all Dutch nationals have the right of abode in the European Netherlands, right of abode in the Dutch Caribbean is limited to those who have a connection to the region. Other Dutch can enter the region visa-free for a maximum of 6 months.[173][174] The identity card BES and the cedula of Aruba, Curaçao and Sint Maarten are valid for entering Bonaire, Sint Eustatius or Saba, but the Dutch identity card is not.[175]
Citizens of other EU/EFTA countries can visit Aruba, Curaçao, Sint Maarten and the Caribbean Netherlands visa-free for 90 days.
See also Andorran nationality law, Monégasque nationality law, and San Marino nationality law.
EFTA countries

See also: Liechtensteiner nationality law

The Nordic Passport Union and the Common Travel Area

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.

Irish and British citizens enjoy freedom of movement in each other's country (Common Travel Area).

The rest of Europe

Note that British citizens do not automatically have the right of abode in the British Overseas Territories, and the visa requirements for British citizens and British nationals vary. See also
Visa policy of the United Kingdom, Visa requirements for British citizens, Visa requirements for British Overseas citizens,
Visa policies of British Overseas Territories, Visa requirements for British Overseas Territories citizens, and
Visa requirements for British Nationals (Overseas)
British citizens have the right to live and work in Ireland.


  1. ^ According to Article 4 of Laws and Regulations Regarding Hong Kong & Macao Affairs, defines Hong Kong residents are persons who qualify for permanent residency in Hong Kong and do not hold a travel document other than HKSAR passport or BN(O) passport; Macau residents are persons who qualify for permanent residency in Macau and do not hold a travel document other than MSAR passport or those who hold a Portuguese passport prior to the end of Portuguese rule.

See also


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  180. ^ Before the dissolution of the Soviet Union in 1991, The Soviet citizenship did not recognize dual citizenship. Who acquires another country's nationality automatically forfeits Soviet nationality.
  181. ^ "Dvojno državljanstvo: 20.000 Banjalučana želi pasoš Srbije". (Serbian; English: Dual Citizenship: 20,000 Banja Luka wants Serbia's passport)
  182. ^ В Раду внесен законопроект, наказывающий за двойное гражданство,; accessed September 7, 2015. (Russian; English: In Rada a bill to criminalize the act of holding two citizenships)
  183. ^ Poroshenko Proposes Bill To Ban Dual Citizenship In Ukraine,; accessed May 6, 2021.
  184. ^ Oleksiy Danilov: Ukraine Needs Law to Control Dual Citizenship,; accessed May 6, 2021.
  185. ^ We plan to allow dual citizenship with EU countries – Kuleba,; accessed May 6, 2021.

Further reading

Council of Europe