Multiple citizenship
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Image:DualCitizenMap.PNG Multiple citizenship, or multiple nationality, is a status in which a person is concurrently regarded as a citizen under the laws of more than one state.
Dual citizenship (being a citizen of two nations), or dual nationality, is by far the most common type of multiple citizenship, but nothing in international law prevents anyone from establishing citizenship in more than two countries. Some countries do not recognise its citizens as having nationality of any other country, or recognise so only in certain circumstances (e.g. Japan recognises only those of underage nationals). Others may recognise as many nationalities as a citizen has.
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Citizenship of multiple countries
Each country has different requirements for citizenship, as well as different policies regarding dual citizenship. An Australian study estimated that 4-5 million Australians (up to 25% of the Australian population - by far the largest group at 1.6 million of these, from the UK) had dual citizenship in 2000. An estimated sixty percent of Swiss nationals living abroad in 1998 were dual citizens. Approximately 89 countries in the world officially allow some form of dual or multiple citizenship. In the United States it is estimated that millions of Americans are also citizens of other countries. Although Germany has a very restrictive nationality law, it does recognise dual citizenship under certain circumstances and the number of dual-citizens was estimated at 1.2 million in 1994. See German nationality law
Because the Republic of Ireland extends its citizenship laws to Northern Ireland which is part of the United Kingdom, people born in Northern Ireland are British Citizens but they may if they wish exercise an entitlement to Irish Citizenship if they so wish by simply applying for a Irish Passport . People Born in Northern Ireland hold either a British passport or a Irish Passport or both. See Irish nationality law and British nationality law
Sub-national citizenship
- The U.S. Constitution also recognizes "dual citizenship" with each of the U.S. states. State citizenship however is informal in practice, and is obtained simply by taking up residence in any given state. (Residents of the District of Columbia do not have dual citizenship, as it is not a state.) There is now almost no legal bearing brought by such an arrangement, except possibly for interstate extradition.
- Switzerland has a three tier system of citizenship - Confederation, canton and commune (municipality).
- Although part of the United Kingdom for British nationality purposes, the Crown Dependencies of Jersey, Guernsey and the Isle of Man have local legislation restricting certain employment and housing rights to those with "local status".
- British Overseas Territories do not have individual 'citizenships' but they do have under their immigration laws a concept of Belonger status which is equivalent. Also see British Overseas Territories citizen
- The Australian territory of Norfolk Island has immigration laws which restrict residence in the territory to those with "local status". Most Norfolk Islanders are Australian citizens
- The Hong Kong and Macao Special Administrative Regions of the Peoples Republic of China make a distinction in their immigration laws between Chinese citizens with the right to reside in the territory and those without. Chinese citizens with right of abode in these territories can hold a different type of Chinese passport which gives more favourable travel rights internationally.
- People from Åland have joint regional (Åland) and national (Finnish) citizenship. People with Ålandic citizenship (hembygdsrätt) have the right to buy property and setup a business on Åland, which Finns without regional citizenship can't. Finns can get Ålandic citizenship after living on the islands after five years and Ålanders loses their regional citizenship after living on the Finnish mainland after five years. See [1] and [2]
- Prior to the dissolution of Czechoslovakia in 1993, Czechoslovak citizens also possessed an internal citizenship of either the Czech or Slovak Republic.
- Before the break-up of Yugoslavia in 1991, Yugoslav citizens possessed an internal citizenship of their own republic (e.g. Serbia, Croatia, Slovenia etc.) as well as Yugoslav citizenship.
Supra-national citizenship
- In European Union law there is the concept of EU citizenship which flows from citizenship of a member state.
- The Commonwealth of Nations has a Commonwealth citizenship for the citizens of its members. Some member states (such at the UK) allow non-nationals who are Commonwealth citizens to vote and stand for election while resident there. However, other member states make little or no distinction between citizens of other Commonwealth nations, and citizens of non-Commonwealth nations.
Issues
There are some legal issues about dual citizenship and government services. For example, an American citizen holding another nationality and passport may have difficulty getting a security clearance if that person prefers to use the non-American passport or work within the United States government. In Canada, conversely, federal cabinet ministers often have dual citizenship with France or the United Kingdom and this in the past has not been an issue to their security clearances.
Although being a citizen of more than one country can be helpful as it affords two or more passports, it is prudent to realise that each citizenship carries responsibilites. This may bring about problems in conscription, as well as allegiance to more than one state. A dual citizen is subject to travel restrictions, embargoes and sets of laws issued by multiple governments governing one's behaviour domestically and while travelling abroad. Also, as a drawback peculiar to a few countries such as the U.S., citizens are obligated to pay taxes in both the country of origin and the actual country of residence. However, many countries and territories have contracted treaties or agreements of avoiding double taxation. For example, as of 2005, Hong Kong has already contracted 33 agreements that address double taxation or its avoidance. In extreme cases, such as when the countries of citizenship are at war with each other, a dual citizen's international status can be very complicated.
The number of multiple citizens is large and increasing. Millions of people in the world are now citizens of more than one country. The number of multiple citizens is going to increase rapidly as people become ever more mobile, living, marrying and having children in multiple countries over the course of their lives.
After 9/11, the security issue was raised of persons with multiple citizenship travelling under different names - having passports under their old and new names from different countries - and using one kind of passport to exit a country, while travelling on another passport in a different name abroad, and not disclosing this travel upon return. Legislation is being prepared in Canada to end this practice, and to identify persons travelling abroad under different names and passports, and identify security threats from such individuals.
It brings important personal opportunities and responsibilities. As a citizen of a country, you have the opportunity to live there, go to school, work, get medical care, have children, buy property, and retire. There may be agreements to allow freedom of movement to other countries, as in the European Union. (Although it takes just permanent residency to enjoy some of these benefits.) There may also be responsibilities connected with citizenship, such as potential mandatory military service.
Examples
Example 1: A person born in Canada, to a Canadian citizen and an American citizen would have Canadian citizenship by birth, and may also have US citizenship, depending on certain circumstances (the parents' marital status, date of the child's birth, and whether the US citizen parent has met certain physical presence requirements). If the requirements have been met, then the child would also be a US citizen, and therefore would have dual citizenship.
Example 2: A person born to American parents in the United States who moves to the United Kingdom may, after five years of legal residence (or three years if married to a British citizen) become a British citizen, and therefore will hold dual British/US citizenship.
Example 3: A child is born in Canada to British born parents. The child is entitled to dual citizenship at birth. Lex sanguinis applies for his British citizenship through his blood relationship with his parents, and lex soli applies for his Canadian citizenship because of his birth on Canadian soil.
Example 4: A British citizen also holds European Union and Commonwealth of Nations citizenship. In addition, most UK citizens born in Northern Ireland are also entitled to citizenship of the Republic of Ireland.
See also
- British nationality law
- Dual citizenship in South Korea
- foreign-born Japanese
- Indian nationality law (including dual citizenship)
- Czech nationality law
- jus soli
- jus sanguinis
- nationality law
- naturalisation
External links
General
- Dual and Multiple Citizenship
- Acquisition of Citizenship: Legal Basis, Naturalization, Dual Citizenship. 178 countries covered.