Dual and second citizenship: is there a difference? Oh yes, if you are seeking an extra passport

What is dual and second citizenship?

The concepts of dual and second citizenship are often used interchangeably. However, from a legal standpoint, these are different statuses that confer different rights and impose different obligations.

Dual citizenship means holding passports from two countries that both recognise your rights and obligations fully. This arrangement typically stems from bilateral agreements, like those Spain has with its former colonies, including Peru and Argentina, among others.

To qualify for dual citizenship, you need to meet specific criteria. These can include having parents from different countries, changes in national borders, adoption by a foreigner, or acquiring citizenship through naturalisation or repatriation.

Second citizenship means having passports from multiple countries without mutual recognition of rights and obligations by those states. Each country sees a dual passport holder solely as its citizen.

Governments might not know about a person's second citizenship unless legally required to disclose it. Where required, non-disclosure can lead to fines or criminal charges.

Typically, any citizenship beyond the first is considered secondary. Ways to acquire this include investment, naturalisation, or marriage.

Advantages and disadvantages of dual and second citizenship

A dual citizen enjoys the rights afforded by both countries but only within the respective country they reside in. For instance, benefits valid in Spain won't apply if the individual lives in Argentina.?

Key perks of dual citizenship include visa-free travel and business operations in both nations, and the ability to seek diplomatic help from either country when abroad.

Dual nationals must adhere to the civil duties of their resident country, such as paying taxes and possibly serving in the military, without the obligation to fulfil these duties in both countries simultaneously.

Take the example of a man with dual citizenship in Spain and Argentina: while residing in Spain, he fulfilled his military duties and paid taxes there. Upon relocating to Argentina, he switched to paying taxes there but was exempt from additional military service.

People often seek a second citizenship to:

• enhance global mobility;
• work internationally;
• secure a fallback option during regional instabilities;
• access better educational and job opportunities for their children;
• benefit from social services in both countries;
• establish overseas businesses;
• and optimise their tax situations.

However, there are drawbacks since each country recognises the individual only as its citizen, which might require fulfilling military duties in both nations. Additionally, holding a second citizenship can restrict high-level governmental employment, such as positions in the prosecutor's office or government or roles involving state secrets.

Countries that allow and forbid second citizenship

Many countries recognise and allow second citizenship , but there are significant variations in their policies.?

Fully permitted. For instance, countries like the USA, UK, Canada, and France permit multiple citizenships without restrictions.

Special cases only. Conversely, some countries, like Austria, Spain, and Norway, only allow second citizenship under exceptional circumstances—such as specific bilateral agreements or special residency conditions.

Strictly forbidden. On the other hand, nations like India, China, and Japan are strict about their single citizenship policy and do not recognise or permit a second citizenship at all.

How to obtain second citizenship

Obtaining second citizenship varies by country and can be achieved through legal residency, marriage, or investment.?

Countries like Vanuatu offer citizenship by investment programs that bypass traditional naturalisation processes, such as language or civic tests. These programs often require investments in government funds, real estate, or local businesses and come with benefits like global mobility, tax optimisation, and, in some cases, expedited access to visas for countries like the USA.

For instance, Caribbean nations like Dominica, Antigua and Barbuda, and St Kitts and Nevis offer citizenship with investments starting at $200,000, providing benefits like visa-free travel to most countries and the ability to conduct business internationally. Similarly, Vanuatu offers one of the fastest paths to citizenship, taking only 1—4 months, with family inclusion and minimum investment requirements based on family size.

In the European Union , Malta allows investors to obtain citizenship by naturalisation for exceptional services by making significant contributions to national development and charitable funds alongside real estate investments.

Besides, Portugal offers investors a residency path that can lead to citizenship after 5 years without stringent residency requirements, demonstrating the diversity in policies related to second citizenship.

Summing up on dual and second citizenship

1. Dual citizenship involves bilateral agreements between countries that recognise the mutual rights and obligations of citizens, whereas second citizenship occurs when a country does not recognise a citizen's obligations to another nation.?
2. Holding dual or second citizenship comes with both advantages, such as increased travel freedom and business opportunities, and potential drawbacks, including obligatory military service or tax liabilities in multiple countries.
3. Countries have varying policies regarding dual and second citizenships, with some allowing them under broad conditions and others imposing significant restrictions or forbidding them at all.
4. The process of obtaining dual or second citizenship can involve different methods, such as naturalisation, investment, or familial connections, each with specific requirements and consequences.

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