What Is Dual Citizenship, and How Does It Work?

What is dual citizenship: USA and Japanese Passports

There are currently 195 recognized countries in the world, and the vast majority of the world’s nearly 8 billion people are citizens of those countries. Some of them are also dual citizens—holding two or more passports.

Dual citizenship means that two countries claim and protect you as one of their own. It can happen when you have parents from multiple countries, or if you’re born in a country other than the one(s) where your parents are citizens.

You can also acquire a second citizenship by being naturalized as a citizen of another country. In some cases, this process may result in dual citizenship.

Different countries treat the question of multiple citizenships differently. Are you interested in becoming a dual citizen? Here’s what it means and what it takes to achieve.

The benefits of dual citizenship

What is dual citizenship: USA and UK flags

One who has dual citizenship must obey the laws of both nations, including laws regarding the payment of taxes to those countries. (Double taxation, though, is often avoided by treaty.) If one or more of your countries has a draft or other type of compulsory military service, you will be subject to those laws as well.

In addition to these responsibilities, there are several benefits of dual citizenship.

1. Consular protection from multiple countries

A dual citizen is entitled to consular protection from each of their countries.

Consular protection means that if you are arrested, run into some other kind of legal trouble, or need assistance while traveling in a foreign country, you can receive aid from your home country’s consulate. Having more citizenships means that there are more people to help, so you have options if you get in trouble abroad.

2. Social programs and entitlements

Citizenship may also come with benefits in the social and legal systems of a given country. For example, United States citizens are entitled to Social Security numbers, which makes them part of a wide-ranging benefit system for injury and retirement and gives them the right to work anywhere in the U.S. In old age, they can also apply for state-sponsored healthcare (Medicare).

Dual citizens can enjoy similar benefits from both of their countries.

3. Passports and travel

Dual citizens can also have a passport for each of the countries where they are citizens. This is important because it gives you greater mobility throughout the world, as foreign passports may be treated differently from those of your home country.

For example, a U.S. passport is generally entitled to the visa waiver program in Japan, so an American citizen can travel there without getting a visa first. An Iranian citizen, however, would have to get a visa for advance permission to travel to Japan, which does not allow waivers for Iranian passports.

The same issue arises with U.S. passports and travel to Cuba, which is difficult without a visa. Someone with Canadian citizenship and a Canadian passport, though, could travel to Cuba much more easily.

A dual citizen, therefore, has extra travel access granted by the passport from their country of citizenship and the passport from their country of origin.

Dual citizenship by country

Certificates of Australian Citizenship and passports

Many countries allow dual citizenship. Countries like the United States, Switzerland, and Australia have been welcoming to the idea, for instance.

The Maastricht Centre for Citizenship, Migration and Development maintains a Global Dual Citizenship Database here that shows data on which countries allow dual citizenship, and in which ways. They note that by 2020, 76% of nations allow their citizens to become citizens of another nation without repercussions.

Not all countries like the idea, however. Japan, Germany, China, and India discourage or forbid the practice.

Japan, for example, allows younger people to have dual nationality/citizenship until they are 22 years old. After their 22nd birthday, however, they must choose one or risk losing their Japanese citizenship. This is also true for naturalized citizens, who generally have to renounce their foreign nationality/citizenship as part of the naturalization process.

When considering dual citizenship, research both countries’ laws. You want to avoid running the risk of losing one of your foreign citizenships when you take the oath of allegiance to a new country.

Common ways to get dual citizenship

Mother and daughter sitting in a park

People usually become dual citizens via three pathways.

Perhaps the most common way to get dual citizenship is to be born with it. In countries with birthright citizenship (jus soli), like the United States or Canada, any person who is born within the country is automatically a citizen regardless of where their parents are from. (Note, however, that the birthright citizenship does not extend to the parents of the newborn.)

Your birth can also give you the right to multiple citizenships if your parent is a citizen of a country other than the one in which you were born. For example, a child born in the United States to a citizen of the United Kingdom is generally eligible to be both a U.S. citizen and a U.K. citizen, with a passport from each country.

You can also apply for citizenship by naturalization. The exact laws differ from nation to nation. In the United States, marriage is a common path to citizenship, as is coming to the country to work. Many countries have residency requirements, and some will require you to renounce other citizenships or nationalities as part of the process.

The difference between citizenship and permanent residence

Dual or multiple citizenship is different from being a permanent resident of a country. Permanent residence status varies by country, but is not the same as citizenship.

In the United States, being a permanent resident means that you’re issued a green card by the U.S. government with many rights, but not all the rights of a full citizen.

Permanent residence is often a path to citizenship by naturalization. A lawful permanent resident can apply for citizenship if they’ve held that status for the past three or five years, for example, under U.S. law. U.S. Citizenship and Immigration Services (USCIS) governs that process.

The difference between citizenship and nationality

Depending on the laws of the countries involved, a person may also have dual nationality. The word “nationality” is often used interchangeably with “citizenship.” This is due in part to interpretation between languages.

Your “nationality” usually refers to your country of origin, not your current residence. “Citizenship” means that you and a country have a unique relationship. As a citizen, you pay income taxes to your country and follow its laws. In return, a country provides citizens with legal protection and social benefits.

The risk of statelessness

One word of caution: the small but real risk of statelessness. Statelessness happens when a person loses all their citizenships, and isn’t considered to have allegiance to (or protection of) any existing country.

Consider this hypothetical example of statelessness: a United States citizen applies to be naturalized as a citizen of a country that requires the applicant to renounce their U.S. citizenship to proceed.

The person does, and obtains citizenship of this new country, which two years later suffers a regime collapse. Now, they are not an American citizen, nor a citizen of anywhere else.

Without consular protection or a right to residence in any one country, life can be difficult. Learn more from the UN Refugee Agency, which is working to end statelessness by 2024.

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