The difference between dual and second citizenship
A person can have the citizenship of several states. In this case, we are talking about multiple citizenship: dual or second. A person can even hold three passports, if the legislation of all three countries allows to become a citizen of another state.
There are dual and second citizenship. Each status has its own advantages and disadvantages.
Dual citizenship involves states recognizing a person's status in both countries. He pays taxes and does military service in his country of residence. Dual citizenship can only be obtained by citizens of countries between which an agreement on dual citizenship has been signed.
The advantages of dual citizenship are the ability to live in any of the countries of citizenship, pay taxes and serve in the army in only one of these countries. A citizen also receives a pension and social benefits only in one state.
If a cosmopolitan acquires the citizenship of a country with which there is no agreement, it is a question of a second citizenship, not a dual one.
Second citizenship assumes that each of the countries considers a person only its citizen and does not recognize his duties in relation to another state.
Second citizenship can be obtained by naturalization if you live in the country for several years as a resident. Some states grant passports for investments in the economy and this way is faster and easier than naturalization.
There are states where it is impossible to obtain a second passport due to the legislation in force there. To become a citizen of one of these countries, you will have to give up your first citizenship. Such rules apply in Germany, Spain, India, China, Singapore.
Second citizenship is obtained for various purposes: to travel without visas, to develop a business, to move to another state. Let's talk about its advantages and disadvantages.
Who are bipatrides?
A bipatride is a citizen of two or more states. The bipatrism was first mentioned in the UN Charter after World War II, when many people became forced migrants.
In the case of dual citizenship, a citizen acquires the legitimate status of a bipatride on the basis of an agreement concluded between the countries.
When a person receives the second, third and subsequent citizenship of any other state, bipatrism arises with a nominal status. The presence of a second passport of a foreign state is not regulated by either federal law or an international treaty.
Advantages of dual citizenship
Recognition of foreign citizenship in the home country. Notification on dual nationality is not required, and therefore there is no risk of fines for failure to comply with the obligation. When crossing the external borders of countries that are parties to the agreement, a bipatride can present a passport of any state.
One-time performance of civic duties. Taxes are paid in the country of permanent residence and the double taxation does not arise. Persons who have completed military service in one state are not subject to conscription in another. Moreover, military duty is considered fulfilled in relation to both countries.
Diplomatic protection. People with dual citizenship have the right to enjoy the protection and patronage of both states. Protection and patronage for them in a third state is provided by any of the two countries at the choice of a citizen. Diplomatic protection on the territory of one of the states of the agreement may be provided to others. In the case of a second citizenship, this principle does not work.
There is an agreement on dual citizenship recognition between Russia and Tajikistan. If a citizen of Russia and Tajikistan ends up in a prison in the United States, then he can seek help from a diplomatic mission or consulate of Russia or Tajikistan in the United States. If a citizen with dual citizenship is detained in Russia, he can seek help in Tajikistan, and vice versa. But if a Russian citizen has French citizenship, then in case of problems with Russia, the French government will not be able to provide support.
Disadvantages of dual citizenship
Few countries with international treaties. Dual citizenship can only be obtained in a country with which the country of first citizenship has an agreement. Most countries in the world have few international agreements on dual citizenship.
Spain is a rare example. The country has concluded dual citizenship agreements with Chile, Argentina, Colombia, Peru, Paraguay, Nicaragua, Ecuador, Bolivia, Guatemala, The Dominican Republic, Costa Rica. If a citizen of any other country wants to become a citizen of Spain, he has to give up his first citizenship.
Few opportunities. Access to quality medicine, prestigious education and the ability to run an effective business is usually provided by citizenship of countries where you can get a second citizenship. For example, the citizenship of countries that are members of the European Union.
Advantages of a second citizenship
Visa-free travel. A second citizenship can open up new travel opportunities if a country has many visa waiver agreements with other countries.
Third-country nationals generally cannot freely visit the UK, the USA, China, or EU countries as they need a visa. Second citizenship solves this problem. For example, cosmopolitans with a passport of any Caribbean country, Vanuatu or Malta visit the Schengen countries and the UK without a visa.
Visa-free travel with a second citizenship
|Citizenship||Number of visa-free destinations||Available popular destinations|
|Malta||185||The Schengen countries, UK, USA, Canada, Australia, Japan, Hong Kong, Singapore|
|Antigua and Barbuda||150||The Schengen countries, UK, Hong Kong, Singapore|
|Grenada||144||The Schengen countries, UK, China, Hong Kong, Singapore|
|Dominica||144||The Schengen countries, UK, China, Hong Kong, Singapore|
|St Kitts and Nevis||157||The Schengen countries, UK, Hong Kong, Singapore|
|Saint Lucia||146||The Schengen countries, UK, Hong Kong, Singapore|
|Vanuatu||135||The Schengen countries, UK, Hong Kong, Singapore|
Better conditions for obtaining a US visa. Second citizenship makes it easier to get a US visa. Citizens of the Caribbean countries receive a B-1/B-2 tourist visa for ten years, citizens of Vanuatu receive a visa for five years.
Citizens of Grenada can get an E-2 business visa. To do this, the applicant opens or buys a business in the United States and invests a significant amount in it. There is no minimum threshold, but usually cosmopolitans invest from $200,000 in a company.
The E-2 visa allows its holder to move to the United States. To get such a visa, an applicant needs to have citizenship of a country which has a special agreement with the USA. Other foreigners can only get a more expensive EB-5 investor visa. The minimum investment amount for it is $500,000.
Study, work and medical treatment abroad. Second citizenship allows to visit some countries without visas, and in some cases, stay there for an unlimited time. Cosmopolitans’ children can do without a student visa or extend the time to look for work abroad.
The time to look for a job after university in many countries is severely limited. For example, in Switzerland you need to get a job within six months from the date of graduation, and in the UK you only have four months. Investors’ children with a second citizenship can live abroad or visit the chosen country without a visa. This increases the chances of employment, because it is easier to come to interviews.
Usually, a medical visa is required for treatment abroad. It is received for a period of two days to several weeks. Second citizenship allows you not to wait and immediately fly to another country for treatment.
If a cosmopolitan with a Caribbean passport needs to urgently go to a clinic in Germany, Switzerland or the UK, he will fly into the country without a visa and stay there for up to 3 months. Malta participates in the US Visa Waiver program, so its citizens do not need a US medical visa for treatment up to 90 days.
Vanuatu citizenship is obtained remotely in 1-2 months, so its documents can be issued even during treatment abroad. This helps to spend the rehabilitation period in comfortable conditions.
Eduard had heart surgery in Germany. Doctors banned him from air travel for a long time. But the visa expired in two months, and the extension was refused. A trip to Russia by car or train would take about two days and the investor’s health was not strong enough for such a long journey. We helped Eduard to obtain Vanuatu citizenship remotely in a month and a half. He was able to leave without a visa to visit his daughter in the UK, and then return to Germany for a medical examination.
Tax optimization. Second citizenship allows its holder to settle in another country, become its tax resident or register a company there. In this case, the cosmopolitan can pay taxes at the rates of the chosen state.
Business development abroad. Businessmen with a second citizenship can open companies abroad. This makes it easier to do business: for example, open accounts in foreign banks and make settlements with partners without currency control.
Caribbean countries do not disclose information about the owners of companies registered there. Data is not entered into the register during registration. The company does not submit reports, does not conduct an annual audit. There is also no currency control in the Caribbean countries.
Opportunity to move to another country. A person can obtain a second citizenship in order to move to a chosen country.
Sometimes a passport gives several alternatives for moving. The Grenadian passport allows to move to this country or obtain an E-2 visa in the United States. Malta is a member of the European Union, so its citizens can move to any state of this association.
Disadvantages of second citizenship
Mandatory notice. Some countries’ legislation requires to notify the government about obtaining a second citizenship. For delay or concealment of information, administrative and criminal liability is provided, e.g. a fine or correctional labor.
Prohibition to work in government agencies. In some countries, citizens with a second passport cannot hold elected office or work in government bodies. They won't be able to become prosecutors, deputies, ministers or judges.
Increased tax rates. A second citizenship by itself may not lead to an increase in the tax burden. Tax rates in the country of the first citizenship can only increase if the dual citizen moves to another state.
If a person spends less than 183 days a year in the country of first citizenship, he ceases to be its tax resident. At the same time, the rate of some taxes may increase.
For emigrated Russians, the personal income tax in most cases is not 13%, but 30%. Non-residents pay this tax if they receive income in Russia. In addition, non-residents cannot receive a tax deduction in Russia.
Difficulties in case of conflict between countries. Since both countries recognize a person only as their citizen, in the event of a conflict, he will have to choose where to perform military service. This is risky: in the second state, you can get under the tribunal.
This disadvantage does not apply to participants of the investment programs. As a rule, neither investors nor their family members are required to serve in the military of the country of the second citizenship.
Where you can and cannot have a second citizenship
Countries may impose the same rules for their citizens and immigrants regarding second citizenship, or pursue different policies. For example, a state may allow foreigners to obtain second citizenship, but prohibit it to its own citizens.
The laws of each state provide for their own conditions and restrictions on the issuance of passports to foreigners, depending on the method of obtaining citizenship. For example, in Germany, obtaining citizenship by naturalization implies the renunciation of the first citizenship. The descendants of ethnic Germans who receive citizenship as immigrants do not have to give up their first passport.
Countries where foreigners can obtain a second citizenship
|Antigua and Barbuda||Bulgaria||Grenada||Libya||Philippines||Sweden|
|Bangladesh||Czech Republic||Ireland||Mauritius||Saint Kitts and Nevis||Turkey|
Countries where a foreigner has to give up his previous passport upon obtaining citizenship
Frequently asked questions
The advantages of second citizenship include:
- freedom to travel to countries where you can not get without a visa with the first citizenship;
- simplified procedure for obtaining a US visa;
- moving to a country with a more pleasant climate or a developed economy;
- development of business abroad;
- tax optimization.
Citizens with a second passport are not entitled to work in the civil service or be elected to government bodies. The exception is cases when the second citizenship cannot be terminated due to circumstances beyond the control of the person. At the same time, in some countries, a civil servant can continue to serve if he does not have access to state secrets. If a citizen moves and ceases to spend 183 days a year in the country of first citizenship, he ceases to be a tax resident. For non-residents, the rates of many taxes are higher. This includes income earned in your home country, such as rental income, profits from the sale of real estate, or dividends on company shares. Sometimes a citizen has an obligation to serve in the army in both states. But usually this does not apply to those who received a passport under an investment program.
Second citizenship is obtained in different ways: people receive a residence permit and live in the country for several years, get married, use repatriation programs. Also, a child can receive two citizenships at birth. To obtain citizenship without long-term residence, you can take part in an investment program. Passports in exchange for investments from $100,000 are issued by the countries of the Caribbean and Vanuatu. In Malta, citizenship can be obtained for exceptional services. To do this, you need to obtain a residence permit and invest from €690,000. The passport is issued after 1 or 3 years from the date of issue of the residence permit card.