Monday, December 23, 2024

Dual Citizenship: Loss of citizenship and renunciation

Dual citizenship refers to a person’s citizenship status, in which a person is concurrently regarded as a citizen of more than one state under the laws of those states. There is no international convention which determines the nationality or citizen status of a person. Citizenship status is defined exclusively by national laws, which can vary and can conflict.

 

Multiple citizenship arises because different countries use different, and not necessarily mutually exclusive, criteria for citizenship

 

Dual citizenship laws are quite complex and vary from one country to another.  The dual citizenship laws must be closely evaluated when acquiring citizenship in a foreign country and cannot be ignored for HNW people.  Some may not even realize that acquiring a foreign citizenship causes losing citizenship of their country of origin. Some countries like Russia, South Africa requires prior permission or must be informed. Some countries require children after reaching 25 get to decide which citizenship to keep. In some countries like Morocco citizenship cannot be renounced.

 

Here are the list of countries and their loss of citizenship and renunciation requirements in 2018 as a result of becoming dual citizen.

 

Afghanistan

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Albania

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Algeria

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Andorra

Automatic loss of citizenship of origin country.

 

Dual nationality is strictly forbidden by Andorran law. On the other hand, Spanish law, though, recognizes dual nationality with Andorra.  If an Andorran citizen serves in the armed forces or government of another country or takes up a foreign citizenship, he/she automatically forfeits his/her Andorran citizenship. Former Andorran citizens may restore their former citizenship if their request to the government is successful.  Any Andorran may live in France without requesting a visa

 

Angola

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Antigua and Barbuda

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Argentina

No automatic loss of birthright citizenship of origin country, and renunciation of citizenship of origin country is not possible. Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

Armenia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Australia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Austria

Automatic loss of citizenship of origin country, and the origin country is Party to Chapter 1 of the Strasbourg Convention.

 

An Austrian citizen who acquires another citizenship by voluntary action automatically loses Austrian citizenship. The exception is in cases where permission to retain Austrian citizenship has been obtained in advance. This may be difficult to obtain, as the aim of the lawgiver is to reduce the number of dual citizenships granted. Exceptions are made for situations where it is in the interest of the Republic of Austria to grant this dual citizenship (e.g. when somebody is a celebrity in arts, sports, science, economy etc.), or in situations where the citizen would suffer hardship due to not having the second citizenship. If, for example, an Austrian citizen wants to obtain U.S. citizenship because he/she lives in the U.S. and, without a U.S. citizenship, would lose their green card due to being made to travel more than 180 days per year by their employer, then if they apply for permission to retain Austrian citizenship, that request is usually granted and has become almost a formality.

The important part is that the application to retain Austrian citizenship is made before acquiring another citizenship. Otherwise the Austrian citizenship is automatically lost the moment a person obtains a foreign citizenship. The law can change at any time, however, especially should the power in the Austrian parliament shift dramatically after an election and a party opposed to the current law regains absolute majority.

Austrian citizenship is also automatically lost by serving in a foreign army.

Restoration of lost Austrian citizenship to Holocaust survivors and their descendants

Azerbaijan

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Bahamas

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Bahrain

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Bangladesh

Automatic loss of citizenship of origin country.

Dual citizenship is permitted under limited circumstances where the person is Bangladeshi not by naturalisation (in other words a Bangladeshi citizen of origin), and the other country which the person is a citizen of one of the following country(s): USA, Australia, Canada, New Zealand or a European country. Such dual citizens of Bangladeshi origin can apply for a Dual Nationality Certificate which makes it legal to use a foreign passport; however people aren’t prosecuted for not applying for such certificate. It is also possible to enter Bangladesh as a person of Bangladeshi origin, or a spouse/children of a person of Bangladeshi origin via an NVR seal on their foreign passports; exceptions include citizens of SAARC countries.

Naturalised citizens are required to relinquish any foreign nationality, and the acquisition of a foreign nationality denaturalises such persons as Bangladeshi citizens.

Barbados

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Belarus

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Belgium

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Belize

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Benin

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Bhutan

Automatic loss of citizenship of origin country.

The Act’s sixth article provides the grounds for forfeiture of citizenship. Bhutanese nationals who become citizens of foreign countries where they reside; who have renounced Bhutanese nationality having settled abroad; who claim to be citizens of a foreign country or who pledge an oath of loyalty to that country; who have naturalized but have since left their agricultural land or stopped residing in Bhutan; or who are bona fide nationals but have stopped residing in Bhutan or failed to observe the laws of Bhutan all forfeit their Bhutanese nationality. This provision emphasizes continual residency as a requirement for citizenship and discourages residency abroad.

The Act’s seventh article provides further grounds for deprivation of citizenship. It states that the government may cancel Certificates of Nationality obtained on presentation of false information or omission of facts. It also provides that the government may deprive citizens of their citizenship without notice if they engage in activities or speech against the King or the people of Bhutan; if they conduct business with, correspond with, or aid enemies during war; and if they are imprisoned in any country for more than one year within five years of attaining Bhutanese nationality. Such a provision is an example of laws on fraud, sedition and treason as well as a policy against allowing serious criminals or convicted felons.

Bolivia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Bosnia and Herzegovina

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Botswana

Automatic loss of citizenship of origin country.

Brazil

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Brunei

Automatic loss of citizenship of origin country.

Bulgaria

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Burkina Faso

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Burundi

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Cambodia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Cameroon

Automatic loss of citizenship of origin country.

Canada

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Cape Verde

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Central African Republic

Automatic loss of citizenship of origin country.

Chad

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Chile

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

China

Automatic loss of citizenship of origin country.

Chinese nationality is automatically lost (or terminated) when a person has settled abroad and pursues one of the following acts (Article 9):

  • Naturalizes as a citizen of another country (regardless of whether the naturalization is involuntary), or
  • Voluntarily acquires the nationality (through naturalization or registration) of another country.
    The term “settled” has the same definition as above.

Outside the circumstances of legally automatic loss of Chinese nationality under Article 9, Article 10 provides for voluntary termination of Chinese nationality under certain circumstances, discussed further below.

For example, a Chinese national who possesses Canadian permanent resident status and who naturalizes as a Canadian citizen loses his Chinese nationality upon the completion of his naturalization because he has voluntarily acquired Canadian citizenship while settled abroad (holding Canadian permanent residency), and any minor children under the age of 18 he might have also loses Chinese citizenship if the children have naturalized as Canadians along with their parent, regardless of whether the children’s acquisition of Canadian citizenship is against their will.

Article 9 is only applicable to Chinese nationals who acquire foreign citizenship while settled in a foreign country.

On the basis of the treaties relating to the return of Macau and Hong Kong to China and the Basic Laws of the territories, the National People’s Congress has issued interpretations of the Nationality Law that deem Hong Kong and Macau, whether before or after their return to China, not to be foreign territory.

As a result, residents of Hong Kong and Macau who would normally be deemed to be Chinese nationals (mainly residents of the two territories who are of Chinese descent) are not deemed to be settled in a foreign country, and so do not lose their Chinese citizenship by virtue of acquiring foreign nationality, whether before or after the return of those territories to China. Even if they are recognized as the national of the foreign country under that country’s laws, the dual citizenship is not recognized by China under Article 3 of the Nationality Law, except for a limited administrative exemption permitting such persons to travel to and from Hong Kong and Macau respectively using the relevant foreign country’s travel documents. As a result, Hong Kong and Macau residents can only satisfy the requirements of Article 9 if they acquire foreign nationality after becoming settled abroad. Alternatively, they can apply to renounce Chinese nationality by virtue of Article 10 of the Nationality Law. This special arrangement applies to Hong Kong and Macau residents; it does not affect the operation of Article 9 in respect of former residents who have become settled in another country and acquire foreign citizenship, as such persons have become settled in a foreign country (and are not resident in Hong Kong and Macau) at the time of legally automatic loss of Chinese citizenship under Article 9. If they return to reside in Hong Kong and Macau, they can notify the acquisition of new nationalities to their respective governments (officially known as the “declaration of change of nationality”), upon which they will be recognized as foreign, rather than Chinese, citizens.

Colombia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Comoros

No automatic loss of birthright citizenship of origin country, but renunciation of citizenship of origin country is possible. Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

Costa Rica

No automatic loss of citizenship of origin country, and renunciation of citizenship of origin country is not possible.

Cote d’Ivoire

Automatic loss of citizenship of origin country.

Croatia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Cuba

Automatic loss of citizenship of origin country.

Cyprus

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Czech Republic

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Denmark

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Djibouti

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Dominica

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Dominican Republic

No automatic loss of citizenship of origin country, and renunciation of citizenship of origin country is not possible.

Ecuador

No automatic loss of citizenship of origin country.

Renunciation of citizenship of origin country is only possible for persons who have acquired citizenship of the origin country by naturalisation.

Egypt

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

El Salvador

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Equatorial Guinea

Automatic loss of citizenship of origin country.

Eritrea

No automatic loss of citizenship of origin country, and renunciation of citizenship of origin country is not possible.

Estonia

Automatic loss of citizenship of origin country.

Estonian citizenship is lost, where he/she is released from or deprived of Estonian citizenship, or where he/she adopts citizenship of another state.

Ethiopia

Automatic loss of citizenship of origin country.

Fiji

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Finland

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

France

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Gabon

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Gambia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Georgia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Germany

Automatic loss of citizenship of origin country.

German citizenship is automatically lost when a German citizen voluntarily acquires the citizenship of another country, except:

  1. When the German citizen acquires a nationality from within the European Union, Switzerland, or another country with which Germany has a corresponding treaty.
  2. When permission to obtain a foreign citizenship has been applied for and granted in advance of foreign naturalization. Failure to obtain so-called permit to retain German citizenship prior to naturalization results in the individual automatically losing German citizenship upon becoming a naturalized citizen of another country. A proposed law called Brexit-Übergangsgesetz  is intended to allow UK nationals who apply for German citizenship before the UK leaves the EU to retain dual nationality.  Many UK and German nationals in each country are supporting the Permanent European Union Citizenship Initiative with the objective of ensuring that Germans taking UK citizenship retain their EU citizenship.

Other cases where German citizenship can be lost include:

  • Persons acquiring German citizenship on the basis of birth in Germany (without a German parent) lose German citizenship automatically at age 23 if they have not successfully applied to retain German citizenship. If it is desired to maintain a foreign citizenship, application must be made by age 21.
  • A German citizen who voluntarily serves in a foreign army (over and above compulsory military service) from 1 January 2000 may lose German citizenship unless permission is obtained from the German government. From 6 July 2011, the permission to serve above compulsory military service is automatically given for the armies of EU, EFTA, and NATO countries and the armies of Australia, Israel, Japan, New Zealand, and the Republic of Korea.
  • A German child adopted by foreign parents, where the child automatically acquires the nationality of the adoptive parents under the law of the adoptive parents’ country. (For example, a German child adopted by Americans prior to 27 February 2001—the effective date of the U.S. Child Citizenship Act of 2000—would not have automatically lost German citizenship, because the child did not automatically acquire United States citizenship by virtue of having been adopted by U.S. citizens.) An exception applies where legal ties to the German parent are maintained.

Ghana

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Greece

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Grenada

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Guatemala

No automatic loss of birthright citizenship of origin country, and renunciation of citizenship of origin country is not possible.

Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

Guinea

Automatic loss of citizenship of origin country.

Guinea-Bissau

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Guyana

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Haiti

No automatic loss of citizenship of origin country. Renunciation of citizenship of origin country is only possible for persons who have acquired citizenship of the origin country by naturalisation.

Honduras

No automatic loss of birthright citizenship of origin country, and renunciation of citizenship of origin country is not possible. Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

Hungary

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Iceland

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

India

Automatic loss of citizenship of origin country.

Section 9(1) of the act provides that any citizen of India who by naturalisation or registration acquires the citizenship of another country shall cease to be a citizen of India. Persons who acquire another citizenship lose Indian citizenship from the date on which they acquire that citizenship or another country’s passport.

Indonesia

Automatic loss of citizenship of origin country.

 

Iran

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

In practice, the Iranian government considers dual citizens as Iranian citizens only. Some Iranian minors may have multiple citizenship. If they wish to retain the non-Iranian nationality after age 18, they have to inform Iran’s Ministry of Foreign Affairs

Iraq

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Ireland

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Israel

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Italy

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Jamaica

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Japan

Automatic loss of citizenship of origin country.

Loss of citizenship requires the approval of the Minister of Justice.

A Japanese national is assumed to have renounced their nationality upon naturalization in any foreign country.Under the revisions made to the Nationality Law in 1985, Articles 14 and 15 require any person who holds multiple citizenship to make a “declaration of choice” between the ages of 20 and 22, in which they choose to renounce either their Japanese nationality or their foreign citizenship(s). Failure to do so entitles the Minister of Justice to demand a declaration of choice at any time. If the required declaration is not made within one month, their Japanese nationality is automatically revoked. A renunciation of foreign citizenship made before Japanese officials may be considered by a foreign state as having no legal effect as is the case with, for example, United States citizenship.

Japanese nationals who hold multiple citizenship by birth, and who do not wish to lose their Japanese citizenship, are required to declare their desire to retain Japanese citizenship by the age of 21. Part of fulfilling this requirement is to “make an effort” to renounce other citizenships once they have declared their intent to retain Japanese nationality. This may be difficult for some Japanese with foreign nationality, for example, Iranian nationals cannot renounce their Iranian nationality until age 25.

A Japanese national does not lose his or her nationality in situations where citizenship is acquired involuntarily such as when a Japanese woman marries an Iranian national. In this case she automatically acquires Iranian citizenship and is permitted to be an Iranian-Japanese dual national, since the acquisition of the Iranian citizenship was involuntary.

Though it is unknown whether it has ever happened, citizenship can also be lost if a person becomes a civil servant of a foreign government, should their role be felt to contradict what it means to be a citizen of Japan.

Jordan

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Kazakhstan

Automatic loss of citizenship of origin country.

In accordance with Article 20-1 of the Law of the Republic of Kazakhstan On Citizenship of the Republic of Kazakhstan, the deprivation of the citizenship of the Republic of Kazakhstan is allowed only by a court decision for the commission of terrorist crimes, as well as crimes provided for in the relevant articles of the Special Part of the Criminal Code of the Republic of Kazakhstan, as a result of which other grave harm was caused to the vital interests of the Republic of Kazakhstan.

In accordance with the article 21 of the Republic of Kazakhstan Law “On Citizenship of the Republic of Kazakhstan” one can lose a citizenship in following cases:

  • as a result of entering military service, security service, police, justice authorities or other bodies of state authority and administration of another state, with the exception of cases stipulated by the interstate treaties of the Republic of Kazakhstan;
    if the citizenship of the Republic of Kazakhstan is acquired as a result of the submission of deliberately false information or false documents;
  • on the grounds stipulated by interstate treaties of the Republic of Kazakhstan;
  • if a citizen has acquired the citizenship of another state;
  • if the marriage with a citizen of the Republic of Kazakhstan, which served as the basis for a person to acquire the citizenship of the Republic of Kazakhstan, is declared invalid by a court;
  • by voluntary will of a child who is a citizen of the Republic of Kazakhstan, transferred for adoption to foreigners, when he reaches the age of majority;
  • due to the participation of a person in foreign armed conflicts, extremist and (or) terrorist activities on the territory of a foreign state.

Kenya

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Kiribati

No automatic loss of birthright citizenship of origin country, but renunciation of citizenship of origin country is possible. Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

Kuwait

Automatic loss of citizenship of origin country.

Kyrgyzstan

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Laos

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Latvia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Lebanon

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Lesotho

Automatic loss of citizenship of origin country.

Liberia

Automatic loss of citizenship of origin country.

Libya

Automatic loss of citizenship of origin country.

Liechtenstein

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Lithuania

Automatic loss of citizenship of origin country.

Luxembourg

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Macedonia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Madagascar

Automatic loss of citizenship of origin country.

Malawi

Automatic loss of citizenship of origin country.

Malaysia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Maldives

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Mali

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Malta

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Marshall Islands

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Mauritania

Automatic loss of citizenship of origin country.

Mauritius

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Mexico

No automatic loss of birthright citizenship of origin country, and renunciation of citizenship of origin country is not possible. Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

Moldova

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Monaco

Automatic loss of citizenship of origin country.

A Monégasque citizen automatically forfeits his/her citizenship if he/she:

  • acquires a foreign nationality
  • performs foreign military service without the prior authorisation of the government of Monaco
  • is deemed to have “harmed the internal or external security” of Monaco

A Monégasque citizen may voluntarily renounce his citizenship.

Former Monégasque citizens may restore their former citizenship if their request on stamped paper directly to the Prince is successful.

Mongolia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Montenegro

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Morocco

No automatic loss of citizenship of origin country, and renunciation of citizenship of origin country is not possible.

Mozambique

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Myanmar

Automatic loss of citizenship of origin country.

Namibia

No automatic loss of birthright citizenship of origin country, but renunciation of citizenship of origin country is possible. Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

Nauru

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Nepal

Automatic loss of citizenship of origin country.

Netherlands

Automatic loss of citizenship of origin country, and the origin country is Party to Chapter 1 of the Strasbourg Convention, as well to the Second Protocol.

As a rule, you will lose your Dutch nationality if you voluntarily acquire another nationality. There are three exceptions to this:

  1. You were born in the country whose nationality you have acquired and that country was your principal country of residence when you acquired its nationality.
  2. As a minor, your principal country of residence for an uninterrupted period of at least five years was the country whose nationality you have now acquired.
  3. You have acquired your spouse’s or registered partner’s nationality.

These three exceptions do not apply if you acquire Norwegian or Austrian nationality, however. In such cases, Dutch nationals will always lose their Dutch nationality due to a treaty with those countries.

You will also lose your Dutch nationality if:

  • after turning 18, you live outside the Netherlands, Aruba, Curaçao, St Maarten or the European Union for longer than 10 years;
  • you hold another nationality during that 10-year period.

In case of minors, if the father or mother loses their Dutch nationality, the child loses their Dutch nationality too.

New Zealand

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Nicaragua

No automatic loss of birthright citizenship of origin country, and renunciation of citizenship of origin country is not possible. Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

Niger

No automatic loss of citizenship of origin country, and renunciation of citizenship of origin country is not possible.

Nigeria

No automatic loss of birthright citizenship of origin country, but renunciation of citizenship of origin country is possible. Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

North Korea

Automatic loss of citizenship of origin country.

The government of North Korea does not recognize dual nationality. However, North Korean citizens who flee to South Korea automatically become South Korean citizens. Also, North Korean citizens who defect to South Korea and become South Korean citizens are not allowed to return to North Korea without special permission and approval from the South Korean government.

Norway

Automatic loss of citizenship of origin country, and the origin country is Party to Chapter 1 of the Strasbourg Convention.3

Oman

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Pakistan

Automatic loss of citizenship of origin country.

Exception: The Government of Pakistan has dual nationality arrangements with following 19 countries.

1 United Kingdom 10 Egypt
2 France 11 Jordan
3 Italy 12 Syria
4 Belgium 13 Switzerland
5 Iceland 14 Netherland
6 Australia 15 United States of America
7 New Zealand 16 Sweden
8 Canada 17 Ireland
9 Finland 18 Bahrain
19 Denmark

Palau

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Panama

No automatic loss of birthright citizenship of origin country, and renunciation of citizenship of origin country is not possible. Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

Papua New Guinea

Automatic loss of citizenship of origin country.

Paraguay

No automatic loss of birthright citizenship of origin country, but renunciation of citizenship of origin country is possible. Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

Peru

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Philippines

No automatic loss of birthright citizenship of origin country, but renunciation of citizenship of origin country is possible. Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

Poland

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Portugal

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Qatar

No automatic loss of citizenship of origin country, and renunciation of citizenship of origin country is not possible.

Romania

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Russia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Rwanda

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Saint Kitts and Nevis

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Saint Lucia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Saint Vincent and the Grenadines

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Samoa

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

San Marino

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Sao Tome and Principe

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Saudi Arabia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Senegal

Automatic loss of citizenship of origin country.

Serbia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Seychelles

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Sierra Leone

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Singapore

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Slovakia

Automatic loss of citizenship of origin country.

Slovenia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Solomon Islands

Automatic loss of citizenship of origin country.

Somalia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

South Africa

Automatic loss of citizenship of origin country.

South Korea

Automatic loss of citizenship of origin country.

South Sudan

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Spain

Automatic loss of citizenship of origin country.

Spanish nationality can be lost under the following circumstances:

  • Those individuals of 18 years of age or more whose residence is not Spain and who acquire voluntarily another nationality, or who use exclusively another nationality which was conferred to them prior to their age of emancipation lose Spanish nationality. In this case, loss of nationality occurs three years after the acquisition of the foreign nationality or emancipation only if the individual does not declare their will to retain Spanish nationality. The exception to this are those Spaniards by origin who acquire the nationality of an Iberoamerican country, Andorra, Philippines, Equatorial Guinea or Portugal;
  • Those Spanish nationals that expressly renounce Spanish nationality if they also possess another nationality and reside outside Spain will lose Spanish nationality;
  • Those minors born outside Spain that have acquired Spanish citizenship being children of Spanish nationals that were also born outside Spain, and if the laws of the country in which they live grant them another nationality, will lose Spanish nationality if they do not declare their will to retain it within three years after their 18th birthday or the date of their emancipation.

Spanish nationality is not lost as described above if Spain is at war.

In addition, Spaniards “not by origin”, will lose their nationality if:

  • they use exclusively for a period of three years their previous nationality—with the exception of the nationality of those countries with which Spain has signed an agreement of dual nationality;
  • they participate voluntarily in the army of a foreign country, or serve in public office in a foreign government, against the specific prohibition of the Spanish Government;
  • they had lied or committed fraud when they applied for Spanish nationality.

People who lose Spanish nationality can recover it if they become legal residents in Spain. Emigrants and their children are not required to return to Spain to recover their Spanish nationality. (Since the nationality law automatically grants Spanish nationality to people born of a Spanish parent, a person born outside Spain to a parent of Spanish birth and nationality who uses the citizenship of the other country exclusively since birth is said to “recover” their Spanish nationality should they apply for it).

Sri Lanka

Automatic loss of citizenship of origin country.

Sudan

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Suriname

Automatic loss of citizenship of origin country.

Swaziland

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Sweden

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Switzerland

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Syria

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Taiwan

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Tajikistan

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Tanzania

Automatic loss of citizenship of origin country.

Thailand

Automatic loss of citizenship of origin country.

Timor-Leste

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Togo

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Tonga

No automatic loss of citizenship of origin country, and renunciation of citizenship of origin country is not possible.

Trinidad and Tobago

Automatic loss of citizenship of origin country.

Tunisia

No automatic loss of citizenship of origin country, and renunciation of citizenship of origin country is not possible.

Turkey

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Turkmenistan

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Tuvalu

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Uganda

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Ukraine

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Ukrainian law currently does not recognise dual citizenship. Ukrainian law states that (after gaining Ukrainian citizenship) the new Ukrainian citizen must renounce its non-Ukrainian citizenship(s) within two years

Automatic loss of Ukrainian citizenship occurs in the event an adult Ukrainian citizen voluntarily acquires a foreign nationality or enters into the military or governmental service of a foreign power.

Ukrainian citizenship is not automatically lost in the following circumstances:

  • Acquiring a foreign citizenship at birth by descent from a parent when Ukrainian citizenship is also acquired by descent.
  • Being adopted by foreign nationals when Ukrainian citizenship was originally acquired by descent from a biological parent.
  • Automatically acquiring citizenship of one’s spouse upon marriage to a foreign national.
  • Automatically acquiring a foreign citizenship upon reaching the age of majority in accordance with the nationality law of a foreign country. In this case Ukrainian citizenship is retained providing that the individual had no formal (documented) knowledge of the automatic acquisition of the foreign citizenship.

https://justicon.ua/en/service/prekrasenie-grazdanstva-ukrainy.html

United Arab Emirates

Automatic loss of citizenship of origin country.

United Kingdom (of Great Britain and Northern Ireland)

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

United States of America

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Section 349 of the INA (8 U.S.C. 1481), as amended, states that U.S. nationals are subject to loss of nationality if they perform certain specified acts voluntarily and with the intention to relinquish U.S. nationality. Briefly stated, these acts include:

  1. obtaining naturalization in a foreign state after the age of 18 (Sec. 349 (a) (1) INA);
  2. taking an oath, affirmation or other formal declaration of allegiance to a foreign state or its political subdivisions after the age of 18 (Sec. 349 (a) (2) INA);
  3. entering or serving in the armed forces of a foreign state engaged in hostilities against the United States or serving as a commissioned or non-commissioned officer in the armed forces of a foreign state (Sec. 349 (a) (3) INA);
  4. accepting employment with a foreign government after the age of 18 if (a) one has the nationality of that foreign state or (b) an oath or declaration of allegiance is required in accepting the position (Sec. 349 (a) (4) INA);
  5. formally renouncing U.S. nationality before a U.S. diplomatic or consular officer outside the United States (sec. 349 (a) (5) INA);
  6. formally renouncing U.S. nationality within the United States (The Department of Homeland Security is responsible for implementing this section of the law, and any inquiries should be directed to DHS) (Sec. 349 (a) (6) INA);
  7. conviction for an act of treason against the Government of the United States or for attempting by force to overthrow, or bear arms against,  the Government of the United States (Sec. 349 (a) (7) INA).

Loss of Nationality and Taxation

P.L. 104-191 contains changes in the taxation of U.S. nationals who renounce or otherwise lose U.S. nationality. In general, any person who lost U.S. nationality within 10 years immediately preceding the close of the taxable year, whose principal purpose in losing nationality was to avoid taxation, will be subject to continued taxation.

Uruguay

No automatic loss of birthright citizenship of origin country, and renunciation of citizenship of origin country is not possible. Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

Uzbekistan

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Vanuatu

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Vatican City State

No automatic loss of citizenship of origin country, and renunciation of citizenship of origin country is not possible.

Venezuela

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Vietnam

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Yemen

No automatic loss of citizenship of origin country, and renunciation of citizenship of origin country is not possible.

 

Zambia

No automatic loss of citizenship of origin country, but renunciation of citizenship of origin country is possible.

Zimbabwe

No automatic loss of birthright citizenship of origin country, but renunciation of citizenship of origin country is possible. Automatic loss of citizenship of origin country for persons who have acquired citizenship of origin country by naturalisation.

 

 

Sources:

Prabhu Balakrishnan
Prabhu Balakrishnan
Founder of Citizenship by Investment News. Chief Editor with over 15 years experience in PR and News publishing. He Loves writing about citizenship, residency and wealth migration. CIP Journal is a Leading publication founded in 2017 bringing latest news from CBI/RBI market.

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