I frequently see statements like “Such and such Country doesn’t recognize dual citizenship” - but what does “recognizing dual citizenship” mean ?
I know there are countries where multiple citizenships are avoided - for example, I automatically lose citizenship in Country A when I voluntarily become a citizen in country B. Or the naturalization process in Country C requires the applicant to renounce any other citizenships. I know it is common (if not universal) for a country to treat all of its citizens the same regardless of any other citizenship so that I can’t avoid military service that is mandatory for Country D citizens simply because I am also a citizen of another country or countries. But I can’t figure out what “recognizing dual citizenship” would mean - would it mean a US citizen could enter the US using another country’s passport or that the US citizen could get assistance from the consulate of the other citizenship ? Or is the whole “doesn’t recognize dual citizenship” just a misleading way to say a country treats all of its citizenship the same?
I think what I’m asking on some level is how is “recognizing dual citizenship” is different from simply not forbidding it and how is “not recognizing dual citizenship” different from making it impossible to exist . I’m asking specifically what people mean by that phrase “recognize dual citizenship” - maybe it just means dual citizenship isn’t legally forbidden but if so, I can’t imagine why they wouldn’t just say that.
If a country does recognize the existence of dual citizenship, it can cause problems for the person involved. For example, when Barnaby Joyce was Deputy Prime Minister in Australia, it transpired that he was also a citizen of New Zealand, which is a problem for elected officials under the constitution.
If, formally speaking, there were no such thing as dual citizenship, then he would not have had a problem: no matter how many countries claimed him as a citizen that would not concern the Commonwealth of Australia.
I understand if to mean that when I take citizenship in country B, country A in which I previously have citizenship automatically revokes it.
As a practical matter country A may not find out that I gave take citizenship in another country and not invalidate my passport (for example), but statutorily you’ve lost your citizenship.
If you go back to China after taking up US citizenship, but not having given up your Chinese passport, you not only could lose consular representation in China, you could be considered to have entered the country illegally. And you do NOT want that.
Is that what “doesn’t recognize dual citizenship” means - that a country simply isn’t concerned with whateverother citizenships one of their citizens holds?
Perhaps I was being too cute with that interpretation. The thing is, some people have three or four citizenships and it is not an issue (unless something goes wrong); it seems to be the default that a country’s laws concern itself with the rights and obligations of its own citizens, and do not say anything about dual citizenship. For example, you won’t get out of military service that way.
There is also the (well-known, I thought?) issue that if you want to join some countries, you have to formally renounce (whatever that means; you will want paperwork proving it at the very least) all foreign citizenship. We can then say that dual citizenship is not allowed in those cases.
Wikipedia has an article on the subject of multiple citizenship. (You can potentially hold citizenship in more than two nations, so “dual citizenship” is an unnecessarily limited term to use for this concept.)
In some countries, having more than one citizenship means they no longer recognize citizenship in that country. In others, it means that you have certain restrictions you wouldn’t have if you were solely a citizen of that nation.
What it means to be “recognized” though will probably depend on context. I don’t think that has any one definition, especially since the matter is handled so differently between different nations, and there is no international standard.
It seems like most of the time, looking at the times when I see the phrase used, it means that the country that recognizes it allows you to be a citizen while being a citizen of another country as well.
If an American citizen gets in trouble in China, they’ll contact the American consulate, and strings will be pulled, and eventually China will agree “OK, we’ll let you take care of this one, America”.
But if a dual American-Chinese citizen gets in trouble in China, they’ll contact the American consulate, and strings will be pulled, and China will say “Screw you, that’s not really one of your citizens, because they’re one of ours”, and they’ll still be in whatever trouble they’re in.
I interpret (no cite) “not recognizing dual/multiple citizenship” as meaning:
This country, of which you are a citizen, does not care at all, positively or negatively, that you may have any other citizenship(s). For all this-country legal purposes you are ours, and exclusively ours. If our stance causes you any issues with other countries, such as having to pay double income taxes to both us and them, that’s all on you.
I am (knock on wood) a few months from securing my Luxembourg passport as my naturalized second citizenship.
I have been warned very clearly not to do this. If you are an American with a second nationality, the US wants you coming into the country on your US passport, period. I’ve been told in no uncertain terms that if I try to present my Luxembourgish passport at a US port of entry, and the border control official does enough checking to verify my original US citizenship (which is probably automated anyway), he or she will take a very dim view of my shenanigans. Like, “take me into a back room for further interviews” dim view, up to “actually no, turn around and go back to Luxembourg.”
Every case is different, so I’ll tell ou mine. YMMV and all that.
I have both the Spanish and the German passports, both legally. I was born in Spain and have a Spanish father (thus the Spanish nationality), and my mother was German, so I received the German nationality too in 1973, when the government of Willy Brandt decided that the German citizenship could be transmitted by the motherly line too (you would think that given that who is the mother is clear while the father may be in doubt and that the German constitution states that both men and women have equal rights this would be a no brainer – you would have been wrong). I was a minor back then. I am male.
Neither Germany nor Spain acknowledged the other nationality, but ignored it. They both pretended that the other passport did not exist. So in fact, I was a Spaniard in Spain, a German in Germany (Western Germany, to be precise) and both in all the other countries (including, funnily enough, the German Democratic Republic). I was allowed to keep both citizenships and passports until the moment I would have to choose. That moment was the draft back then (today both countries have a voluntary army, something which may change again). Both countries had laws that stated in clear terms that citizens of Spain/Germany were under no circumstances allowed to be members of the armed forces of another country. That would be considered almost treason! Back then Spain was not yet a member of NATO, BTW.
Then at the age of 17 (before the Spanish draft took effect, that would have been at the age of 18) I moved to Berlin (West), where German men were not drafted due to the special status of the city after WWII (long story). So I did not have to chose between the two citizenships/passports and I have kept both ever since: I did not have to serve in Spain, because I lived abroad, and I did not have to serve in Germany, because I lived in Berlin.
I always thought that this was unfair because women did not have to do military service, so it was easier for them to keep both nationalities. Now that in both countries there is no longer a draft (until that changes again, looking at you, Putin ) the situation is fairer.
A friend of mine tried to head to the US on her Irish passport as her American one had expired. She was refused entry, but luckily that was at Shannon Airport in Ireland where they do pre clearance.
Another friend with 4 passports used to find it amusing to always leave a country using a different passport to the one he entered on. Most countries don’t really care, but he never tried that in the US.
If a country A recognizes dual citizenship then it recognizes the other country’s (B) sovereignity over a citizen over which it also claims to have that sovereignty. If this country then revokes this recognition all it is saying then is that that citizen in question is from that moment on only subject to the laws of country A, no longer of country B. Country B may disagree, but would be powerless to do anything about that within the borders of country A.
What country A may not do by force of the UN convention on citizenship or something like that is deprive a citizen of country A of this citizenship, leaving the citizen stateless (or high and dry, as you put it), independently of whether the citizen in question has another citizenship, particularly if country A does not recognize this citizenship B.
It may try to force the citizen to choose, for instance with a law that forbids something that a citizen must do if he keeps both citizenships, like military service (see my previous post).
I had a friend / co-worker who was a US-born US citizen. His Dad was a European who’d emigrated to the USA. The son got whichever Euro-country citizenship his Dad had by right of inheritance. So the kid (my friend) was dual-citizen US + whichever Euro. This was before the EU.
Now while my friend was a teen, Dad worked for the US State Department and gets stationed at an embassy in Canada. So although the kid did not have Canadian citizenship, he did have ongoing Canadian resident status as a result of living in Dad’s household.
Looking for a part-time job, he got involved in some civilian auxiliary to the Canadian armed forces. Which did not amount to joining the forces. Except for when an unscrupulous recruiting sergeant gave them all a form to sign to join the real Canadian military Reserves instead. Oops.
The USA revoked his passport & citizenship for joining a foreign military as soon as they found out. Which did not take long. Even his Dad working at the Dept of State could not beat that rap.
At least prior to 01/20/2025 it was pretty darn hard for a US-born natural US citizen to have their US citizenship revoked. He found one of the few ways to do it. Oops.
) the situation is fairer.