Dual citizenship explained
Dual citizenship is a complex legal status. Read our guide to better understand what dual citizenship is, its benefits and other essential information.
Free ConsultationFor most of us, our citizenship status is determined at birth.
For example, those born in the UK to British parents will be British citizens. And for many, our citizenship at birth is the one we carry with us our whole lives.
However, with the rise in popularity of citizenship by investment (CBI) programmes, being a citizen of more than one country is becoming increasingly more common.
So, it’s no surprise that the number of people searching for the term ‘dual citizenship’ has consistently increased over the last decade, according to data from Google Trends.
But what is dual citizenship?
This article answers that question and examines the benefits of dual citizenship, as well as other essential information you need to know about this complex legal definition.
What is dual citizenship?
Dual citizenship, also known as dual nationality, occurs when a person is legally recognised as a citizen of two countries at the same time. It is based on bilateral agreements that are in place between two countries.
However, it is important to note that not all countries recognise dual citizenship, and it must be accepted by both states for a person to be a dual citizen. Data shows that globally, less than half (49%) of countries allow dual citizenship.
You should also be aware that dual citizenship is different to second citizenship.
Having second citizenship means being a citizen of two countries at the same time. The difference is that one country does not recognise the other. This means each country considers a person as its citizen and not a citizen in two separate countries.
That may sound complicated, but think about it this way: As a dual citizen, your citizenship status in country A works in harmony with country B. With a second citizenship, rather than working together, they are treated as independent of one another.
Now we know what dual citizenship is, how do you become one?
How can I become a dual citizen?
There are several ways you can become a dual citizen. The two most common ways are through birth and by descent, both of which you have no control over.
However, there are additional routes to securing foreign citizenship.
Naturalisation
You can become a citizen of another country through a process called naturalisation.
Naturalisation occurs when you have lived in a country as a permanent resident for several years. After this time, and provided that criteria are met, you can apply to become a citizen of that country.
There are a number of residency by investment (RBI) schemes that provide a route for investors to become citizens through naturalisation.
Numerous RBI schemes, such as the EB-3 and EB-5 visas in the USA, allow residents to apply for citizenship after several years. In Europe, the popular Portugal Golden Visa (PGV) provides a route to EU citizenship within five years.
Citizenship by investment (CBI)
Citizenship by investment (CBI) programmes allow foreign nationals to become citizens by making a financial contribution or investing in a country
The minimum investment amount varies depending on the option and the programme selected.
These schemes provide a clear pathway for investors and their families to secure citizenship in a foreign country. They are one of the quickest ways to become a citizen and much faster than naturalisation.
What are the benefits of dual citizenship?
Citizens have more rights in a country than residents. Some examples of the benefits of dual citizenship include:
Freedom of movement
One of the primary benefits of dual citizenship is the ability to travel more freely. As a dual citizen, you can hold two passports, meaning visa-free travel to more countries, which makes travel less restrictive.
Voting rights
Dual citizens have full voting rights in both countries, meaning they can have a say in elections.
Business opportunities
Dual citizenship can open up a broader range of business opportunities. This is because citizens are able to do business in both countries. Also, citizens of certain countries have the right to work in any member state of economic and political unions, such as the European Union (EU).
Family benefits
Some countries allow citizens to sponsor family members, allowing them to also become citizens. Citizenship can also be passed down to children.
Tax benefits
Some countries have more favourable systems and offer tax advantages. Dual citizens benefit from lower tax burdens.
Be aware that this is a double-edged sword. As a dual citizen, you are subject to double taxation unless a double tax treaty exists between the two countries. Speak to a tax specialist to ensure you are tax-efficient while complying with cross-border tax laws.
What countries allow dual citizenship?
Many countries worldwide allow dual citizenship, including the USA, EU, and Caribbean states. However, not all countries allow it.
Remember, to become a dual citizen, both countries must allow it. Below is a list of the countries that allow dual citizenship.
| Albania | Algeria | Angola* | Antigua and Barbuda |
| Argentina | Armenia | Austria* | Australia |
| Bangladesh | Barbados | Belgium | Belize |
| Benin | Bolivia | Bosnia and Herzegovina* | Botswana* |
| British Virgin Islands | Brazil | Brunei* | Bulgaria* |
| Burkina Faso | Burundi | Cambodia | Cameroon* |
| Canada | Cape Verde | Central African Republic* | Chile |
| Colombia | Comoro Islands | Congo (Republic) | Costa Rica |
| Cote d’Ivoire | Croatia* | Cyprus | Czechia |
| Denmark | Djibouti | Dominica | Dominican Republic |
| Ecuador | Egypt* | El Salvador* | Equatorial Guinea* |
| Fiji | Finland | France | Germany* |
| Georgia* | Greece | Ghana | Grenada |
| Guatemala | Guinea-Bissau | Haiti | Honduras |
| Hong Kong | Hungary | Iceland | Iraq |
| Ireland | Israel | Italy | Jamaica |
| Jordan | Kenya | Kosovo | Kyrgyzstan |
| Laos | Latvia | Lebanon | Lesotho* |
| Liberia* | Lithuania* | Luxembourg* | Macao |
| Madagascar* | Malawi* | Mali | Malta |
| Mauritius | Mexico | Micronesia* | Moldova* |
| Montenegro | Morocco | Namibia* | Nauru* |
| Netherlands* | New Zealand | Nicaragua* | Niger* |
| Nigeria* | North Macedonia* | Norway* | Pakistan* |
| Palau | Papua New Guinea | Paraguay | Peru |
| Philippines | Poland* | Portugal | Romania |
| Russia | Samoa (American) | Samoa (WS) | Scotland |
| Serbia | Seychelles* | Sierra Leone | Solomon Islands* |
| Somalia | South Sudan | Slovakia* | Slovenia* |
| South Africa | South Korea* | Spain* | Sri Lanka* |
| St. Kitts and Nevis | St. Lucia | St. Vincent and the Grenadines | Sudan |
| Sweden | Switzerland | Syria | Taiwan (Chinese Taipei) |
| Tajikistan | Thailand | The Gambia | Timor-Leste |
| Tonga | Trinidad and Tobago* | Tunisia | Türkiye |
| Uganda | United Kingdom | United States of America | Uruguay |
| Vanuatu | Vatican City | Venezuela | Yemen* |
| Zambia | Zimbabwe |
*Under certain circumstances
Securing citizenship with Holborn
With increasing global mobility and the rise in popularity of investment schemes designed to fast-track the citizenship process, it is more important than ever to understand what dual citizenship is and its pros and cons.
Citizenship by investment programmes can offer foreign nationals numerous benefits and fast-track the process of becoming citizens. The first step that potential investors should take is to seek expert advice.
Holborn Pass is an international leader in investor visas and a part of the wider Holborn Assets Group. Our experienced team provides a bespoke, end-to-end service and tailored advice to support your needs.
We have successfully helped hundreds of people and their families secure golden visas and citizenship. Book a consultation with one of our advisers to find out how we can help you secure yours.
Frequently asked questions
Dual citizenship is the status of someone who is a legal citizen of two countries at the same time. This means they have two passports and hold rights in both states, including the right to vote, work, and live in either country.
Dual citizenship can complicate tax obligations. Some countries tax citizens on worldwide income, regardless of where they live. This can lead to dual citizens being taxed by both countries on the same income. However, many countries have tax treaties to prevent double taxation. It is recommended that dual citizens consult a tax specialist to ensure they are as tax-efficient as possible and comply with tax laws.
Many countries allow dual citizenship. However, you can only have dual citizenship if both countries allow it. It’s important to check the specific laws of each country.
It is technically possible to have triple citizenship. However, it all depends on the legislation and rules of each country in question. Having multiple citizenships can also cause complications, so speak to an expert to find out how it could impact you.
Dual citizenship and second citizenship are two different things. Both refer to being a citizen of two countries. However, with second citizenship, each country considers that person to only be a citizen of that country and not of another.