Second citizenship

Who dual citizens are and what rights and responsibilities they have

If someone holds more than one citizenship, they are called dual citizens or dual nationals. Dual citizenship is permitted in many countries, though the government often consider such citizens as subjects of only their countries.

This article discusses which legal consequences the status of a dual citizen entails.

What a dual citizen means

Dual citizens are persons who hold more than one citizenship. They can be divided into two groups:

  1. Those with the legitimate status of dual nationals in both countries. It is possible when their countries of citizenship have signed a treaty on the settlement of issues of dual nationality. For example, this happens to a person who holds an Argentinian and Spanish passport. 
  2. Those with formal status. It is possible when holding dual citizenship is not regulated by either federal law or an international treaty. For example, this happens to a person with American and Maltese passports. 

The rights and responsibilities of dual citizens depend on which group described above they belong to.

Dual citizenship. If countries have signed a treaty on dual citizenship, they recognise the rights and responsibilities of a dual citizen in relation to each other.

A man with dual citizenship of Spain and Argentina lived in Spain; therefore, he served in the Spanish army and paid taxes to the budget of this country. Having moved to Argentina, he begins to pay taxes there, but his military service no longer needs to be served.

Second citizenship can be obtained in a country that has not signed an agreement on dual citizenship with the country of your first citizenship. In this case, both countries of citizenship consider such persons only their citizens, and the fulfilment of civic responsibilities in one country does not count in the other.

Differences between dual and second citizenship 

ConditionDual citizenshipSecond citizenship
Agreement on dual citizenship recognition between the two countries
Legitimate status of a dual citizen in both countries
each country considers a person only its citizen
Both countries of citizenship recognise the dual national’s rights and responsibilities in relation to each other
fulfilment of civic responsibilities in one country does not count in the other

Benefits of dual and second citizenship

Advantages of being dual national depend on the countries this person holds citizenship. Dual citizenship allows living, working, studying, and receiving allowances and pensions in the selected country. Second citizenship can provide more benefits than dual one. Let us discuss them.

Visa-free travel. Second citizenship makes it possible not to waste time obtaining visas and travelling even during the pandemic. Maltese passport holders, as well as citizens of Caribbean countries, are allowed to visit the UK and Schengen Area without visas. Maltese citizens also travel visa-free to the USA, while Caribbean citizens obtain long-term visas to visit this country.

Health care. Citizenship of an EU country permits to apply to public medical institutions of the union and use medical services free of charge or at reduced prices.

Education. Best schools and universities are situated in the US, UK and EU. Second citizenship may help children get a good education and job, with their parents having no obstacles to visiting them.

Moving to another country. Dual citizens can choose to live in a country with a warmer climate, better ecology, more attractive fiscal system and broader opportunities for doing business. Citizenship of the Caribbean allows you to go on vacation to a warm country at any time. With a Maltese passport, you can choose any EU country to live in.

benefits of dual citizenship
In Portugal, investors can obtain residence permits and, after five years, apply for citizenship. The climate of this country is characterised by about 300 sunny days a year

Doing business. Second citizenship allows you to open a company abroad and promptly travel to business meetings. For example, a Grenada passport gives visa-free access to 144 countries, including Singapore, the UK and China. Citizens of Grenada can obtain a B-1/B-2 tourist visa to the United States for 10 years, as well as an E-2 business visa.

Citizenship for the whole family. Citizenship by investment programs allow to include family members in the application: a spouse, children and parents, as well as grandparents, brothers and sisters in some cases. Relatives will become dual citizens at the same time as the investor.

Malta citizenship for life, studies and work in the EU

Before obtaining Maltese passports, the investor and his family held a residence permit in Germany. Though, this status did not match their needs.

Maltese passports allow our clients to:

  • live and study in any country of the EU;
  • apply for jobs in the EU on an equal basis with EU citizens;
  • retain their first citizenship.
Client’s story

Disadvantages of dual and second citizenship

The drawbacks of being dual citizens are connected with responsibilities towards the countries of their citizenship. Besides, many countries impose restrictions on dual citizens.

No career in politics. This applies to both the country of origin and the country of second and subsequent citizenship. A person with dual or second citizenship is not entitled to work in government bodies or have access to state secrets. The ban on work in state bodies is imposed due to a threat to the state’s internal security.

Military service. Those who have obtained second citizenship become liable for military service in both countries of their citizenship. Service in one country's army does not eliminate the obligation to serve under conscription in the other. 

The exception is dual nationals who obtained a second passport by investment: neither the investor nor his children are subject to conscription in the country of second citizenship.

For persons with dual citizenship, service in the army of one state is recognised in the other one. They do not have to serve twice.

Penalty for non-fulfilment of civic obligations. A fine is imposed for the failure to vote in Austria, Australia, Belgium, Bulgaria, Brazil, Greece, Egypt, Luxembourg, Turkey, Pakistan, and other countries. In some countries, ignoring the duties of voters provides for a jail sentence.

Responsibility for the failure to vote in different countries

CountryFineOther punishment
Australia$13. If you refuse to pay, the fine increases to $50Community service orders, seizure of property, or imprisonment for 1—2 days
Argentina$20 to $200 Prohibition of work in government bodies for three years
Belgium€50 for first non‑attendance, €125 for a repeat offenceThe fourth non‑attendance results in disenfranchisement for 10 years and prohibition of work in government bodies
Luxembourg$80 for first non‑attendance, $240 for a repeat offenceImprisonment for one month to a year
Pakistan$60 Correctional labour
Germany€70 

Which countries allow dual citizenship and which do not

Many countries allow their citizens to hold multiple citizenships. However, they consider dual nationals only as their own citizens and do not recognise their rights and obligations in relation to other states.

Obtaining a US passport is accompanied by an oath, which at first glance obliges you to give up your first passport. Here is a quote from the Oath of Allegiance: "I hereby declare, on oath, that I absolutely and entirely renounce and abjure all allegiance and fidelity to any foreign prince, potentate, state, or sovereignty, of whom or which I have heretofore been a subject or citizen."

However, in the case of acquiring US citizenship, there is no real need to renounce the citizenship of another country. The United States considers dual nationals solely as citizens of their country.

Where a foreigner can obtain second citizenship without giving up the first

AlbaniaBelizeFinlandKosovoNigeriaSouth Korea
AlgeriaBoliviaFranceLatviaPakistanSri Lanka
AngolaBrazilGreeceLebanonPanamaSt Kitts and Nevis
Antigua and BarbudaBulgariaGrenadaLibyaPhilippinesSweden
ArgentinaChileHong KongLuxemburgPortugalSwitzerland
ArmeniaCosta RicaHungaryMalawiRomaniaSyria
AustraliaCyprusIcelandMaltaRussiaTunisia
BangladeshCzech RepublicIrelandMauritiusSerbiaTurkey
BarbadosDenmarkItalyMexicoSloveniaUSA
BelgiumDominicaJamaicaNew ZealandSouth AfricaVanuatu

Some countries do not allow multiple citizenship. If a citizen of one of these states acquires second citizenship, he loses the right to the first. The first citizenship does not terminate automatically: you must apply for renunciation of citizenship.

In Spain, it is banned to hold second citizenship. To become a citizen of the country, you need to give up the passports of other states. The exception is citizens of France, Andorra, Portugal, the Philippines, Equatorial Guinea and some Latin American countries, who can obtain dual citizenship with Spain.

There are countries where it is almost impossible for a foreigner to get a second passport: due to the small territory of the country, the high population density, or the culture closed to foreigners.

Vatican City is the smallest country on earth. About 800 people live there, 450 of whom are citizens of the state. The country follows one of the most challenging immigration policies in the world. Only cardinals residing in Vatican City or Rome, diplomats representing the Holy See, or employees of the Catholic church can obtain Vatican City citizenship.

Liechtenstein is a mountainous country between Austria and Switzerland with a population of about 40 thousand people. The country's passport is issued after 30 years of continuous residence or, in case of marriage registration to its citizen, after 5 years.

There are no immigration programs in Liechtenstein. Each case of applying for a passport is considered individually. Factors of importance that influence the decision are the country of origin, financial situation, real estate ownership in Liechtenstein and meritorious service to the state.

China. The Nationality Law of the People's Republic of China allows foreigners to become citizens of the country only if their relatives are Chinese citizens. The state is overpopulated, so there are no other real ways to get a passport. Naturalisation is possible, but the law does not mention the time necessary to live in China.

In the legislation of some countries, there are differences between foreigners who want to obtain citizenship of this country and their own citizens who get a passport of another state. For example, if a foreigner wants to become an Egyptian citizen, the law does not require the renunciation of the other citizenship. But if an Egyptian decides to become a citizen of a foreign state, his Egyptian passport will be renounced.

The most difficult dual citizenship
To become a citizen of Bhutan, a foreigner needs to live in the country for 20 years, know the history and culture, as well as read and write Dzongkha, the official language of the kingdom

How to become a dual national

It is possible to obtain dual or second citizenship on the following grounds:

  1. You were born abroad or to parents who hold citizenship of different countries.
  2. You have married a citizen of another country.
  3. You have been naturalised after long-term residence in the territory of a foreign state.
  4. You have made investments in the country's economy.

Citizenship by birth. There are two main methods for determining the citizenship of a child born in a foreign country:

  1. “Jus sanguinis”, or by blood. A child’s citizenship depends on their parents’ one. It does not matter in which country the child was born. 
  2. “Jus soli”, or by soil. The child acquires citizenship of the country they were born in. It does not matter which country’s citizenship their parents hold.

Method "jus soli" can be applied unconditionally, as in the United States, or with the qualifications on parents' citizenship, as in Germany.

If a child is born in the US and both of his parents are, for example, citizens of Turkey, then this child obtains two citizenships: Turkish and American. If a child is born in Germany, they acquire German citizenship if only at least one of his parents is German. If both parents are foreigners, the child gets the citizenship of the parent’s country of origin.

In many European countries they apply the method "jus sanguinis". Children born of foreigners in the UK, Greece, Portugal, Ireland and Spain receive only the citizenship of their parents, regardless of the country of birth.

Child's Second Citizenship: Canada
In Canada, they apply the principle "jus soli': all children born in Canada become citizens of the country

Marriage. Marriage should not be fictitious. In many countries, they tighten legislation and, within several years, check whether the spouses are really in a close relationship. You will not be able to apply for citizenship immediately after the wedding: the legislation of many countries assumes that the couple should live together for several years.

A spouse of an Italian may apply for citizenship after being married for at least two or three years, depending on the couple’s place of residence. The term is halved if a child is born in the family.

Dual national: second citizenship by marriage
If for five years, you have been married to a Swiss and lived together in the country, you become eligible for citizenship

Naturalisation. The rules for acquiring citizenship by naturalisation depend on the country's legislation.

The naturalisation procedure includes several stages:

  1. A foreigner legally enters the country. For this purpose, they receive, for example, a work or study visa or a visa for financially independent persons.
  2. After legal entry, you can apply for a residence permit.
  3. A few years later, you get the right to apply for permanent residence or immediately for citizenship.

Citizenship by investment allows you to become a dual national quickly — starting from one month. Applicants are usually offered several investment options. Family members can be included in the application.

Citizenship by investment: the fastest way to become a dual citizen

Citizenship programs allow to get a passport by investing in the country's economy. An equally reliable but longer option is to participate in temporary or permanent residence programs to obtain a second passport in the future.

Citizenship by investment. Citizenship by investment programs are approved by the government of the country. Depending on the program's conditions, you can invest in real estate, business, and other assets.

Countries investors can receive citizenship in

CountryInvestment amountTimeframe to obtain a passport
Malta€690,000+ 1 to 3 years
Montenegro€472,000+6 months
Turkey$250,000+6 to 8 months
St Kitts and Nevis$150,000+ 2 to 6 months
Grenada$150,000+ 4 to 6 months
Vanuatu$130,000+ From 1 month
Antigua and Barbuda$100,000+ 3 to 6 months
Saint Lucia$100,000+ 3 to 4 months
Dominica$100,000+ 3 to 6 months

Temporary or permanent residence by investment. The procedure for obtaining citizenship for participants in the residence programs takes more time than for investors who acquire a second passport.

You can become a Portuguese citizen after five years of getting a residence permit. Yet you need to spend in the country only seven days a year. You can apply for Greek citizenship after seven years of living in the country.

Residence Permit and Permanent Residence Programs 

Residence Permit
CountryInvestment amountTimeframe to obtain a status
Malta€30,000+3 to 4 months
Portugal€250,000+2 to 6 months
Greece€250,000+3 months
Andorra€400,000+2 months
Spain€500,000+2 to 3 months
Permanent Residence
Malta€150,000+6 to 8 months
Cyprus€300,000+2 to 24 months depending on the category of participation 

Citizenship and residency by investment can only be obtained with the help of a licensed agent: it is required by the law. Immigrant Invest has received accreditation from the governments of the European Union and Caribbean countries.

Who stateless persons are

Stateless persons are people who do not hold any citizenship. They can be born in a family of stateless persons or lose citizenship during life.

One can become a stateless person if:

  1. They are born into a family where both parents are stateless. However, if they are born in the country where the principle "de soli" is applied, they acquire citizenship.
  2. They renounce their citizenship. For example, this may happen when a person is going to get citizenship of another country. Until they obtain proof of identity in the new country, they are considered stateless.
  3. They are sentenced to lose citizenship for committing crimes, from the harmful effects of which the state wants to protect its citizens.
  4. They have their passport annulled because they obtained it illegally.
  5. The country of their citizenship de jure and de facto ceases to exist.
  6. There arises a conflict of nationality laws. For example, a woman loses citizenship in some countries if she marries a foreigner. If her husband's country does not grant her citizenship immediately, she becomes stateless.

Frequently asked questions

What are the ways to become a dual national?

To become a dual national, you need to obtain second citizenship in any other country. Among the methods of getting a second passport there is naturalisation, repatriation, and investment in the country’s economy.

To newborns, the principle “jus soli” can be applied. In this case, a child born in a foreign country acquires citizenship of that country by birth.

In which country can I get second citizenship by investment?

In the Caribbean, Oceanian and European countries. The programs differ in amounts of investment and terms of participation. A Vanuatu passport can be obtained within 1—2 months. The process of acquiring citizenship in the EU countries takes 4—6 months.

Immigrant Invest helps obtain a second citizenship or residence permit by investment in the Caribbean, Oceania and the European Union.

Who cannot hold dual citizenship?

As a rule, the president, deputies, governors, auditors, judges and other civil servants with access to state secrets are prohibited from holding second citizenship or a residence permit in another country.

Is it possible to have multiple citizenship?

Yes, it is. If a country allows its citizens to have more than one passport, their number no longer matters: you can obtain two, three or more citizenships.

Can a US citizen have dual citizenship?

Yes, they can. US citizens may get second citizenship and become dual nationals. When foreigners obtain US citizenship,  there is no need to renounce the citizenship of another country. Yet, the United States considers dual citizens solely as citizens of their country.

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Who dual citizens are and what rights and responsibilities they have