Second Citizenship: What is it and How to Obtain it?

Countries around the world offer foreign nationals the chance to become permanent residents and obtain another citizenship through descent, naturalization, marriage, investment, or other means. Dual citizenship allows individuals to access benefits from both nations by holding valid passports from each country. Acquiring dual citizenship is possible through ancestry, marriage, and naturalization and this article explores how it works and what you need to apply.

What is Second Citizenship?

Dual citizenship is the status of an individual who holds multiple citizenships, meaning they are citizens of two or more countries. The concept has ancient roots and has evolved due to historical, legal, and political factors.

In the 19th century, mass immigration raised questions about citizenship, leading to some countries allowing immigrants to retain their initial citizenship.

In the 20th and 21st centuries, globalization and advancements in communication and transportation have made it more common for people to have ties to multiple countries, leading to an increase in individuals obtaining passports from other countries.

You should always keep in mind that each country has its own dual citizenship rules and regulations. Some countries fully recognize and accept dual citizenship, while others may have restrictions or limitations on holding dual or triple citizenship and multiple passports.

Dual citizenship can offer various benefits, such as:

• The ability to live and work in multiple countries
• Visa-free access to more destinations
• Enhanced consular protection
• Expanded social services

However, it can also present challenges, particularly when it comes to issues like taxation, military service obligations, and legal responsibilities.

Dual Citizenship Advantages

Any individual who can obtain a second passport in a foreign country and unlock their dual national status can access all the benefits and rights of both nations. These include:

By holding dual citizenship, you won’t need a visa to stay in the countries you hold citizenship. Depending on a country’s agreement with other nations, second-passport countries provide visa-free travel to more destinations than what is available with just one passport.

This makes dual citizenship particularly powerful in EU countries since EU passport countries offer freedom of mobility within the European Union and the right to live and work there indefinitely.

Ways to Obtain Dual Nationality

Contrary to popular belief, you cannot just ‘buy’ dual nationality. You have to earn it, depending on your unique circumstances and objectives. In general, you can get another passport in four ways:

By birth

If you were born in a foreign country that grants citizenship by “jus soli” (right of soil), you may hold a claim to acquire citizenship based on being born in the country. Typically, nations that practice jus soli grant citizenship automatically to any child born within their territory.

United States: The United States Constitution declares any child born on US soil as an American citizen regardless of their parent’s citizenship or residence status.

Dominica: Like the US, Individuals born in the Commonwealth of Dominica receive citizenship at birth.

By descent

Citizenship by descent is commonly known as “jus sanguinis” (right of blood), whereby an individual is granted citizenship or has the right to claim citizenship through a blood relative who holds citizenship in the respective country. This means that the acquisition of citizenship is based on a familial connection, typically through parentage, rather than the individual’s place of birth.

Ireland: Ireland’s citizenship law allows individuals with a natural-born Irish parent or grandparent to apply for Irish citizenship.

Italy: The criteria for Italian citizenship by descent are expansive, permitting individuals with Italian ancestors in the direct line to apply for Italian citizenship without any generational limitations.

Through marriage

Being married to a citizen is a common route foreigners pursue to become dual citizens. It adheres to the guidelines for naturalization, often with streamlined requirements, including a reduced residency period and no language proficiency prerequisites.

Spain: Foreigners spouses of Spanish nationals can apply for Spanish citizenship by marriage after one year of residency instead of the standard ten-year naturalization period.

Cape Verde: Cape Verde allows the spouse of Cape Verde nationals to request citizenship without first obtaining residency.

By naturalization

Naturalization refers to the set of requirements a foreign national must satisfy to attain citizenship in a particular country. The primary basis for naturalization is a specified period of legal residence. This typically entails obtaining a residence permit and transitioning to permanent resident status before applying for citizenship after completing the required term of residence. Naturalization can also include demonstrating knowledge of the country’s customs and proficiency in one of its official languages.

Peru: Peru has one of the world’s shortest naturalization periods, with just two years of legal residence qualifying foreign nationals to apply for citizenship by naturalization.

Portugal: Portuguese foreign residents are eligible for permanent residence or European citizenship after five years of residency.

By fast-track naturalization

Commonly known as citizenship by exception, the decision to award accelerated citizenship is often at the discretion of a head of state or ruling government body. There are no concrete guidelines for obtaining or awarding fast-track citizenship; however, the decision usually revolves around making substantial contributions to the country’s development, be it economic, educational, or cultural.

United Arab Emirates: The UAE Executive Regulation of the Federal Law concerning Nationality and Passports introduced new criteria for granting citizenship based on exceptional merit. Experienced individuals in fields such as scientific research, the arts, and medical care may be offered UAE citizenship at the discretion of royal UAE authorities.

Serbia: The Republic of Serbia has a discretionary program that may grant Serbian citizenship by exception to individuals deemed to have contributed significantly to Serbian society. Considerations can include contributions to education, business, or the possession of substantial assets in the Republic.

By investment

A few countries have introduced Economic citizenship programs worldwide, allowing foreign investors who contribute to their economies to receive second passports and become dual citizens. These initiatives typically involve significant financial investments, such as real estate purchases, job creation, or contributions to specific economic sectors, providing an avenue for individuals to secure dual citizenship by actively contributing to the host country’s economic development.

Antigua and Barbuda: The Antigua and Barbuda citizenship by investment program is one of the most affordable dual citizenship programs, with a $100,000 contribution to the country’s National Development Fund (NDF) or $200,000 real estate purchase qualifying investors for citizenship.

Vanuatu: Vanuatu grants citizenship within 60 days to foreign nationals who contribute $130,000 to the country’s government fund.

Reclaiming Citizenship

Historically, numerous countries maintained a hard-lined stance on dual nationality. Many citizens, uprooted by war or exiled due to discrimination, found themselves losing their citizenship upon settling in foreign nations.

Countries like Germany and Spain have implemented distinct citizenship laws and regulations, allowing individuals who lost their citizenship due to uncontrollable circumstances to regain citizenship.

At the same time, foreigners with ancestors who were natural-born citizens of specific countries may hold the right to acquire their ancestor’s former citizenship.

Certain countries have abolished specific citizenship laws that once prohibited individuals from accepting second passports or required them to obtain permission before obtaining a second passport.

The South African government required South Africans to obtain permission from the Minister of Home Affairs to retain their South African citizenship before seeking citizenship from other countries.

However, the requirement was ruled unconstitutional by the country’s supreme court, and citizens no longer need to file a retention of citizenship claim. Additionally, South Africans who had lost their citizenship based on the previous rule can reclaim South African citizenship.

How to Get Dual Citizenship: CBI Programs

If you were born abroad or hold no familial ties to a country, the best way to get a second passport is through citizenship by investment programs (CBI) – also commonly known as ‘passport by investment’ or ‘economic citizenship.’

Several countries have begun offering investment migration programs such as citizenship by investment and Golden Visa programs to foreigners and their family members, with an aim to draw them into their economies by granting residency and citizenship rights.

Qualifying individuals can obtain second passports through a CBI program in exchange for a financial contribution such as a donation to a development fund or investment in real estate, directly contributing to the respective nation’s economy. Real estate investments are typically the most popular route of dual citizenship programs. However, as each country’s government has its own set of regulations regarding investment migration, not all offer the real estate route.

Best passport by investment

Most CBI programs offer a direct path to citizenship by investment; however, some provide an expedited naturalization process, allowing investors to reduce the naturalization period required to obtain a second passport.

For example, while you can directly acquire dual citizenship via the St Kitts and Nevis citizenship program in as little as four to five months, you’ll have to wait between 12 to 36 months to prove your naturalization in Malta before acquiring Maltese citizenship. Our citizenship by investment comparison guide provides a detailed view of available economic citizenship programs, including their investment requirements and the time to citizenship.

Malta citizenship by naturalization

Often inaccurately referred to as the Malta citizenship by investment program, the Malta Granting of Citizenship for Exceptional Services Regulations (CES) provides non-EU nationals and their immediate family members with citizenship rights by means of naturalization.

To qualify, applicants must place a minimum investment of €690,000 in the country’s economic development through a set of three investments, including a real estate purchase or lease, a government contribution, and a philanthropic donation. The program also requires applicants to pass a stringent due diligence process.

Successful applicants become eligible for citizenship by naturalization and a Malta passport within 12 to 36 months, depending on their investment. After obtaining citizenship, they gain a second passport and the right to live, work, and study in the island nation, as well as other countries in the European Union.

Caribbean citizenship by investment

Caribbean citizenship programs are appealing options for foreign investors looking to acquire passports quickly and cost-effectively. Starting from as low as $100,000, you can get dual citizenship in countries like Dominica or St Lucia, with excellent visa-free travel options and various tax benefits.

Many Caribbean countries have no residency requirements, meaning you don’t have to go to the country and live there to qualify for citizenship after your investment.

Caribbean citizenship is priceless. It offers top benefits, including:

• Luxury pre-approved property investments at affordable prices
• Idyllic lifestyle on picturesque islands
• Visa-free travel to over 140 countries
• Option to apply for passports remotely
• No residence, stay, or language requirements
• Excellent tax package
• Geographical proximity to the US

With so many Caribbean CBI programs available, a thorough Caribbean citizenship by investment comparison will help you understand the various investment routes, requirements, and timeframes to citizenship.

Citizenship via Golden Visa Programs

Suppose you’re not in a rush to acquire dual citizenship but are looking for a quick way to get temporary residency first in another country. In that case, applying for the Golden Visa is a perfect option.

 Portugal Golden Visa

Portugal is an attractive destination for citizens seeking a peaceful yet vibrant place to call home. The country’s appeal lies in a combination of attributes — pleasant weather, captivating landscapes, sun-soaked beaches, and a short naturalization process.

The Portugal Golden Visa program creates a pathway to European citizenship after five years of residency. The investment options that take you to permanent residence or Portuguese citizenship are:

• The creation of at least ten jobs
• €500,000 toward research activities by scientific research institutions integrated into the national scientific and technological system
• €250,000 toward artistic production, recovery, or maintenance of national cultural heritage
• €500,000 in establishing a new company or the share capital of existing companies, alongside job creation
• €500,000 contribution to Portuguese investment funds

Spain Golden Visa

You can also consider Spain’s Golden Visa program. It is possible to get a Spanish nationality after going through the Golden Visa program and maintaining your investment as well as your permanent residency in the nation for ten years.

Spain offers fast-track naturalization to only citizens of Ibero-American countries, the Philippines, Andorra, Equatorial Guinea, Portugal, and France. Citizens of these countries can acquire citizenship after two years of residency, in addition to the right to keep their original citizenship.

Countries That Prohibit Dual Nationality

Globally, most countries recognize dual citizenship, but a handful of nations don’t. For various reasons, these countries will outright deny your request for foreign passport and, in some cases, compel you to renounce the citizenship of your home country before you acquire citizenship of another country and a second passport.

China: China does not officially recognize dual citizenship. If Chinese citizens acquire foreign citizenship, they are generally considered to have renounced their Chinese citizenship. However, China does have provisions for individuals of Chinese descent born abroad to acquire Chinese citizenship while retaining their original one.

This is typically done through applying for the Chinese “Huaqiao” or “Overseas citizen” status. This status does not grant the full rights of a Chinese citizen, but it does allow for certain privileges.

India: India does not allow dual citizenship in the strictest sense. However, it does recognize the concept of Overseas Citizenship of India (OCI) and Persons of Indian Origin (PIO) cards. These schemes provide certain privileges to Indian citizens living abroad, akin to some of the benefits of Indian citizenship, but without conferring full citizenship status.

Japan: Japan does not allow for dual citizenship for adults as Japanese law generally requires individuals to choose one nationality and renounce any other citizenship by age 22. However, there is an exception for dual citizenship for children.

Children born with dual citizenship (for example, if they are born to parents of different nationalities) are not required to choose one nationality until they reach the age of 22. At that point, they must decide which citizenship to retain.

Singapore: Singapore does not allow dual citizenship. If a Singaporean citizen acquires foreign citizenship, they are generally required to renounce their Singaporean citizenship.

Singaporean law is explicit about this policy, and individuals who hold dual citizenship are expected to renounce their foreign citizenship upon becoming Singaporean. Failure to do so can lead to various consequences, including revoking Singaporean citizenship.

Argentina: Argentina generally does not allow dual citizenship for Argentinians or anyone seeking Argentinian citizenship. However, there are exceptions for citizens of specific countries. Argentina has dual citizenship agreements with Italy and Spain based on historical ties, meaning Italian and Spanish nationals are eligible to obtain dual citizenship status in Argentina.

Netherlands: The Netherlands does not allow dual citizenship. Dutch law states that if a Dutch citizen voluntarily acquires foreign citizenship, they typically lose their Dutch citizenship.

However, there are several exceptions and situations where dual citizenship is allowed, such as children born to parents of different nationalities in the Netherlands, Dutch citizens who marry a foreigner and acquire their spouse’s nationality, and non-EU/EFTA citizens who become Dutch citizens through naturalization can sometimes retain their citizenship.

Saudi Arabia: Saudi Arabia does not officially recognize or allow dual citizenship. If a Saudi citizen acquires foreign citizenship, they are generally considered to have renounced their Saudi citizenship.

It’s important to note that Saudi Arabia’s citizenship laws and policies are stringent, and acquiring citizenship in another country can lead to the automatic loss of Saudi citizenship. In practice, individuals who acquire foreign citizenship are often required to surrender their Saudi passports.

Malaysia: Malaysia does not allow anybody to be a dual citizen. If a Malaysian citizen acquires foreign citizenship, they are considered to have renounced their Malaysian citizenship.

Israel: Israel does not allow its citizens to hold dual citizenship in most cases. Israeli law generally requires individuals to renounce their foreign citizenship upon becoming an Israeli citizen.

However, there are exceptions and special circumstances, particularly for certain individuals who acquire Israeli citizenship through the Law of Return (which grants Jewish people the right to immigrate to Israel). In some cases, these individuals may be allowed to retain their original citizenship alongside their Israeli citizenship.

Second Citizenship as an American

The United States does not explicitly have a law that addresses dual citizenship. Instead, it follows the principle of “jus soli,” which grants citizenship to anyone born within the territorial boundaries of the United States, regardless of the nationality of their parents.

When a foreign national becomes a US citizen through the process of naturalization, they are not required to renounce their original citizenship, nor does it actively discourage the holding of dual citizenship.

They can maintain multiple citizenships with their home country and any other country, provided each country allows dual citizenship.

As a dual citizen of the US, you are also entitled to a passport, as the US government issues a valid US passport to all American citizens, including those with dual or triple citizenship.

Tax Benefits of Dual Citizenship

Acquiring dual citizenship can offer various tax benefits to individuals, depending on the countries’ policies. Some countries with citizenship through investment programs provide favorable tax regimes, including lower income tax rates, exemptions on foreign income, and reduced capital gains taxes. Vanuatu is a perfect example; successful applicants of Vanuatu’s citizenship by investment program are subject to no personal or corporate income taxes, and companies must only pay an annual fee.

Although Americans are subject to citizenship-based taxation, they can substantially reduce their tax liability by acquiring citizenship in a low-tax jurisdiction and leveraging the tax exemptions provided to overseas US citizens.

The strategic selection of dual citizenships can thus serve as a powerful tool for managing and optimizing taxes, offering increased financial flexibility and enhancing overall wealth preservation and succession planning.

What is double taxation for dual citizens?

Double taxation in the context of dual citizenship refers to an individual being subject to taxation in two different countries on the same income or assets. This can occur when a person is considered a tax resident in both countries due to citizenship or residency status.

Countries often form bilateral tax treaties or agreements to mitigate double taxation. These treaties aim to prevent or alleviate the issue of double taxation by providing guidelines on which country has the primary right to tax specific types of income or assets. They may also include provisions for tax credits or exemptions to prevent or reduce double taxation.

For individuals with dual citizenship, understanding the tax laws and treaties between their countries of citizenship or residence is essential. Seeking advice from tax professionals or consulting official government sources can help individuals navigate their tax obligations and potentially take advantage of any available relief measures.

Avoiding Second Passport Scams

Sadly, the increasing interest in obtaining second passports has given rise to an industry of scams and purveyors of false information. These include:

Diplomatic passports: Previous scandals in countries such as Ecuador have seen individuals illegally obtain diplomatic IDs. Diplomats are held to specific global standards, and even in countries with more lenient criteria for second passports, awarding such a prestigious recognition is unlikely.

Canceled CBI programs. As new second-passport countries with citizenship through investment programs emerge, others that once had programs no longer offer them. Montenegro had a citizenship through investment program; however, the initiative was suspended at the end of 2022. Therefore, companies offering citizenship and immigration services to acquire Montenegro citizenship through investment are providing a service for a program that no longer exists.

Camouflage passports: Espionage has a link to camouflage passports, initially provided to Americans working in high-risk locations. There are passports from countries that no longer exist, like Swaziland or Rhodesia. However, some fraudulent websites claim you can obtain citizenship in a country that changed its name years ago, which is false.

Gray market passports: Engaging in bribery with an immigration official at a passport agency to secure passports and inserting unqualified names results in what is commonly referred to as a “grey market passport.” Gray market passports may or may not be entered into the official system; however, holders of gray market passports face the looming threat of potential criminal prosecution should their illicit activities come to light.

Black market passports: Black market passports fall under the purview of scammers and possess no legitimacy whatsoever. They could be stolen or counterfeited passports or as simple as replacing passport photos and information.

Second Citizenship and Legal Considerations

The legal implications of dual citizenship and a valid passport in two countries can vary widely. While tax advantages may be attached to dual citizenship, there can be negative tax implications that come with multiple citizenships, depending on the countries involved.

Another duty of citizenship to consider is military service. Some nations legislate conscription, and citizens of a certain age may have to fulfill military service. If you hold multiple citizenship in countries with mandatory enlistment, you may find yourself subject to military service obligations in both nations, necessitating careful consideration of how these requirements align and potentially affect your personal and professional life.

How Can Global Citizen Solutions Help You?

Global Citizen Solutions is a boutique migration consultancy firm with years of experience delivering bespoke residence and citizenship by investment solutions for international families. With offices worldwide and an experienced, hands-on team, we have helped hundreds of clients worldwide acquire citizenship, residence visas, or homes while diversifying their portfolios with robust investments. 

We guide you from start to finish, taking you beyond your citizenship or residency by investment application. 

Frequently Asked Questions about Second Citizenship