Citizenship – what is it and how is it important?

Flags of the world – Image by S. Hermann & F. Richter

The topic of citizenship comes up time and again for those who are looking to expand their options for places to live, visit, and manage their affairs. In this article, I’ll talk about the basics of citizenship, as well as where it can trip you up if you fancy going on a citizenship acquisition spree.

WHAT IS CITIZENSHIP

“Where are you from?” is a typical opening question that expats are used to asking and answering, almost daily. This question (rightfully or wrongfully) provides a myriad of information for the person asking, and can often help further the conversation. At other times, it might feel like a form of pigeon-holing.

For many people, their citizenship has a huge influence on their lives and their options. Your citizenship aligns you with a specific country, including the requirement to comply with its laws and customs. Typically, it confers the right to live and work and conduct your affairs as you see fit, provided you are keeping everything above board. Your citizenship also has a greater or lesser effect on you as you age, and when you travel.

Interestingly, unless you are tied to the United States (or Eritrea), your citizenship of itself doesn’t have a direct impact on your taxation. Taxation is most directly influenced on where you spend time, and where you do business / earn money.

HOW DO I GET CITIZENSHIP

This is a little more involved than you’d expect, and I’ll drill into each of the options and their relative applicability. The four “standard” ways of acquiring citizenship:

Note that these options are either available to you at birth, or through your own actions over time. Here are the other means to obtain citizenship that can become available to you as an adult. As you read this list, you can imagine that some are going to be easier than others:

Let’s step through each option. Bear in mind that some of this information is included for completeness and may never apply to your circumstances.

TYPES OF CITIZENSHIP

Citizenship by birth

Some countries in the world still honour the legal notion of jus soli, regardless of the citizenship and / or visa status of your parents. This means that from the moment you become a legal entity (i.e. when you’re born), you are automatically deemed a citizen of the country that you are born in. If you happen to be born on a cruise ship in international waters, in Antarctica, or another place not properly recognised as a country, things get a little more difficult.

However, for most of us, where the woman that gave birth to you was on the day that you took your first breath is your default starting citizenship (try saying that sentence twice). This inalienable right to citizenship based on where you are born has prompted many women over the years to make the journey to countries that could confer a “better” citizenship on their (yet unborn) child.

The United States was famous for this, with the mother allowed to stay in the country to look after the child. Such children earned the moniker of “anchor babies”, and became the ticket to a new world for their parents.

Nowadays, countries such as Brazil are potential destinations for mothers to give birth in a bid to obtain Brazilian citizenship for their child. The birth right to citizenship by virtue of being born somewhere is becoming increasingly uncommon. This is in response to the aforementioned “anchor baby” concept, and for other reasons.

Mentioned in this section for completeness is citizenship by adoption. An adopted child can often obtain the citizenship of their adoptive parents.

Citizenship by ancestry

What happens if the country you are born in doesn’t afford you the right of jus soli? This can be surprisingly common, and so the fallback position is to look to your parents. Most countries allow their citizens to pass on citizenship to their offspring, particularly for men to their children.

For some countries, this right can be passed down a few generations. This had led to the eager-minded tracing back the family tree to see what options might be available.

For many countries that don’t allow dual citizenship, there is typically a provision to allow children to obtain the country’s citizenship up to the age of 18. At this point, the child (now adult) will need to make a choice which citizenship to retain.

Naturalisation

This is the most common way that people obtain citizenship when they didn’t already acquire it through birth or inheritance. How long it takes to become a citizen of a country varies, as does the eligibility requirements.

Some countries have requirements that largely are based on the time spent in the country, as well as a demonstrable ability to speak the language of the country. Others are looking for an even closer alignment with their culture, and so require observance of a particular faith (e.g. most Gulf nations), or limited to a specific ethnic background (e.g. Hong Kong).

Investment

As a way to inject funds into the local economy, more countries are choosing to offer this route to citizenship. There can be controversy surrounding this practice, with some believing that it devalues what it means to be a citizen. Others take the attitude that as long as the country profits from these newcomers, then who cares?!

Whilst the amount required to invest and other hoops to jump through vary by country, the crux is this: bring cash, and no significant issues (crime, terrorism, etc), and they’ll welcome you with open arms.

Citizenship by investment can be attractive for several reasons, including:

Whilst this option is typically out reach for the average person, there are still several options are still in the six-figure price range.

Marriage

Finding that special somebody is life-changing for most people.What if marriage threw in an option to obtain your partner’s citizenship as well, would that sweeten the pot? Long is the list of stories of people marrying in order for one party to remain in a country.

Whilst this may (or may not) be tolerated by society, the immigration department of most countries will put you and your partner through the ringer when you apply to get married. This is to confirm that your marriage is legitimate before the path to citizenship becomes available. Children are an excellent sign that your union is the real deal.

For those not yet on that path, it can be a little trickier to prove the validity of the relationship. One tip that can help a future immigration application based on marriage is to ensure that you take lots of photos of you as a couple as your relationship matures. Ideally, changing hair styles every couple of months definitely helps the photos show the length of the relationship too.

Law of Return

After the atrocities meted out on the Jewish people (and others) during World War II, the newly-formed state of Israel enacted a Law of Return in 1950. This right guarantees that all Jewish people around the world can obtain Israeli citizenship, and residency in Israel. By providing citizenship, Jewish people would be able to obtain travel documentation to reach Israel if desired.

The Israeli state has on many occasions provided support in repatriation for those in need. The Law of Return also applies to those who have converted to Judaism, and those married to a Jewish person (including same-sex marriages).

Sephardi Jewish ancestry – Spanish or Portuguese citizenship

This is, in very simple terms, a variation on the theme of citizenship by descent. In 1492, Spain and Portugal expelled their Jewish population, known as Sephardi, as Catholicism took root. Five centuries later, reparations have been offered for those whose ancestors were forced to flee or convert to Catholicism.

This came in the form of the opportunity to apply for Spanish or Portuguese citizenship, under separate programs. However, the strict eligibility requirements and processing time has meant that very few (a few thousand) successful applicants have acquired citizenship of either country.

Act of parliament, or act of a sovereign

This is largely honorific in nature. Citizenship is typically awarded to those who have made (or can make) a significant contribution to the country. Countries will do this from time to time, and such citizenship grants often are featured in the news.

An example of a famous person receiving citizenship is actress Angelia Jolie, who obtained Cambodian citizenship due to her humanitarian works. She has gone on to direct an excellent film, First they took my father, shot entirely in the Khmer (Cambodian) language, covering the early days of the Khmer Rouge.

Shifting gears rather dramatically, some small states bereft of Olympic-level football talent will grant citizenship to promising players. This allows these countries to create a team to qualify and potentially place in the Olympics.

In some monarchies, the king or queen can award citizenship to individuals that they believe will make a good addition to their realm.

Temporary honorific citizenship

We are now stepping into the realm of rarefied options. In the bulk of cases, obtaining these citizenships is by-product or a formality associated with performing other duties.

The first example is Vatican citizenship, conferred on serving members of the Catholic clergy that are based in the Vatican city. This is known as jus officii, and is temporary in nature. You’ll need to be a Cardinal appointed to Rome to join the club.

Even more limited is the Sovereign Military Order of Malta (not to be confused with the EU country Malta), a micro-state that is also located in Rome, and awarded under similar circumstances as above. Unlike Vatican citizenship, you are unlikely to be able to use this citizenship to travel far. Many countries don’t recognise their passports, including UK, US, and New Zealand.

Limited citizenship

Some countries recognise the value of their diaspora being able to retain some closer connection with the “home” country. In particular, former citizens who “trade up” citizenships to a less restrictive citizenship (from a global standpoint).

An example of this is the Overseas Citizen of India (OCI), which is available to any non-Indian citizen with a close familial tie to India. This means that if you, your parents, or grandparents were born in India, you can become an OCI. And, if you happen to marry an Indian citizen or an OCI holder, you too can become an OCI after two years of marriage.

An OCI isn’t consistently seen as a citizenship of itself, and isn’t a travel document (i.e. you will still need a passport of another country).

Separately in this category are citizenships of countries that are not universally recognised. This means that whilst your country will allow you to travel, you may not be able to enter many other countries (or even obtain visas).

WHAT ARE THE OBLIGATIONS AND LIMITATIONS OF CITIZENSHIP?

After reading about these various options, some of you might be wondering, “What’s the catch?” Well… if you are born a citizen, and you live your entire life in that country without traveling anywhere, not many. Chances are there are no downsides or limitations that you’ll ever have to deal with.

Given that you’ve made it so far in this article, this scenario doesn’t apply to you. There are a few things that can become a limiting factor or a downright burden over time.

Taxation

Possibly what draws most people to read this type of article to begin with. Your citizenship can play a defining role in where you will personally need to pay taxes. This is where most people can get tripped up; the devil is in the detail.

There are (currently) only two countries in the world that impose taxation on worldwide income – the United States and Eritrea. Simply being a citizen of any other country is of much less relevance to your personal tax situation than where you spend your time, and where you earn your money.

That being said, if you have one citizenship (which is most people), your default situation will be that you are expected to pay taxes in your “home” country. The various ways and means to not pay taxes in the home country are topics for other articles. However, if you are only an Australian, or only British, assume that the ATO or HMRC wants a cut of your action for as long as they can get away with it.

In essence, your citizenship will determine the default country that you will be expected to pay tax in. The burden falls on you to demonstrate alternative arrangements, should the tax authorities come knocking.

Military service

As of the start of 2020, there are currently 28 countries that have mandatory military service for citizens. In some case, Permanent Residents are also included in this requirement. All compulsory military service requires participation from male citizens, with civil service options in some countries for conscientious objectors (i.e. are against military efforts).

In 11 of the 28 countries, women are also expected to participate in compulsory military service, mostly for a lesser period than men. Depending on your age, this may or may not be a burden for you.

If you however want to confer your citizenship onto your children, it could have unintended consequences. For example, if you (or your child) were to become a citizen of two countries with compulsory military service, this will likely become an issue. This is because both countries may prohibit you from serving in another military, creating legal complications.

Travel restrictions

Restrictions on travel based on your citizenship is unfortunately quite common for many countries. Your own country may prohibit you from entering another country, particularly if there is ongoing war / conflict / tension. An example is countries that prohibit their citizens from entering North Korea (such as Malaysia, and the United States).

What is more common is the restriction or inability to obtain visas to visit another country. Again, this typically stems from conflict / terrorism reasons, or religious ideological reasons.

DUAL (OR MULTIPLE) CITIZENSHIP LIMITATIONS

In addition to the above obligations, having two or more citizenships can come with other limitations. The following may never impact your life, depending on what you do in life. Noted here for awareness:

Unable to hold elected office

A number of countries restrict dual-nationals from holding elected office. If elected (or going through the process), you may be required to renounce your other citizenship(s). Australia has recently run into this challenge with a number of politicians possessing foreign citizenship.

Security clearance

Obtaining security clearance is important (or core) for a number of government jobs in most countries (if not all). This isn’t just for aspiring James Bonds out there! Security clearance can be required for a wide range of private industry roles as well, particularly government-facing work.

Holding dual nationality, particularly if the countries are friendly, may not be a show-stopper for security clearance. However, it will likely prevent you obtaining top clearance, and potentially impact job role prospects.

For those working in the private sector, or running their own businesses, this is unlikely to ever be a factor.

Automatic loss of (or need to surrender) citizenship

This can happen in a few ways (ignoring any wrongdoing on your part). If you obtained citizenship of some countries at birth through a parent, they may allow dual citizenship up to 18. Some also may have requirements around residency before turning 18, or language fluency.

Some countries take a strict stance around single nationality (e.g. most Asian countries). Therefore, if you choose to naturalise as a citizen in many countries, you will have to renounce previous citizenship(s) held.

QUICK NOTES ABOUT PASSPORTS

Acquiring citizenship doesn’t necessarily mean access to a passport. In addition, being a citizen doesn’t always come with a right to have a passport. And, a passport can be revoked without impact on citizenship. This happens in extreme circumstances, usually associated with criminal offences. If you choose to naturalise as a citizen, you often have to separately apply for a passport.

Lastly, you can generally only exist as a citizen of one country at a time, inside a country. Some countries, such as the USA and Australia, require that citizens pass through immigration only as a citizen. In this scenario, you can never enter these countries using a visa. It also means that if you have services such as US Global Entry attached to a British passport, you can’t utilise that feature if you enter the USA as an Australian citizen for work purposes.

The other impact of this is embassy / consular support. If you enter a country (e.g. Vietnam) as a citizen of one country (USA), then that country’s (USA) embassy is the one that you can reasonably expect support from. Even if you are also a New Zealand citizen, their (New Zealand) embassy is unlikely to want to help you.

SUMMARY

We’ve walked through the basics of citizenship in its various flavours. There are various ways to obtain citizenship, some requiring more effort / circumstances. We have scratched the surface of a number of pertinent topics for those seeking additional citizenship(s).

Your motivations for being interested in other citizenships may be to solve a particular issue (e.g. travel restriction). Or it could be to change your circumstances for where you want to spend time. In any case, do bear in mind the restrictions and limitations that sometimes come with becoming a dual (or more) national.

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