For decades, Germany adhered to a strict principle: a German passport generally required renouncing all others. The Citizenship Law (Staatsangehörigkeitsrecht) was based on the idea of preventing multiple citizenships (Vermeidung von Mehrstaatigkeit). However, in 2024, a tectonic shift occurred. The Federal Republic radically reconsidered its approach, recognizing the realities of a globalized world and its status as a country of immigration (Einwanderungsland).
What is dual citizenship?
Dual or multiple citizenship (Mehrstaatigkeit) is a legal status in which a person is simultaneously recognized as a citizen of two or more states. Each of these states grants them a full set of rights and imposes corresponding obligations. This is not just the possession of two passports for travel; it is a full-fledged legal connection with multiple legal systems.
Countries that prohibit or restrict dual citizenship often appeal to the idea of singular loyalty. They fear conflicts of interest, especially in matters of national security, diplomatic protection, or military service obligations.
On the other hand, states that accept multiple citizenship see it as a tool for integration and attracting talent. In a world where millions of people live, work, and create families outside the countries of their birth, the requirement to renounce their “native” passport creates an emotional and legal barrier. By allowing both statuses to be retained, the country of acquisition facilitates naturalization and promotes fuller integration of immigrants into society.
Revolution in German Legislation: Reform of 2024
Until 2024, the answer to the question “Is it possible to have dual citizenship in Germany?” was predominantly negative, but with many exceptions. The new law (often referred to as Modernisierung des Staatsangehörigkeitsrechts or StARModG) fundamentally changed this paradigm.
Previously, the German citizenship law required that a foreigner wishing to become German renounce their previous citizenship. Similarly, a German who voluntarily acquired the citizenship of another country (not EU/Switzerland) automatically lost their German passport.
Exceptions existed. Citizens of other EU countries and Switzerland could always keep their passports. Exceptions were also made for citizens whose countries do not allow renunciation of citizenship (for example, Iran, Afghanistan) or make this process excessively humiliating or expensive.
For Germans wishing to obtain, for example, American or Canadian citizenship, there was a complicated path. To keep their German passport, they needed to prove “continuing ties” (fortbestehende Bindungen) with Germany.
This process was called “Application for Retention of German Citizenship” (Antrag auf Beibehaltungsgenehmigung). The applicant had to convince the authorities that their ties to Germany (family, economic, property) remained sufficiently strong, and obtaining a second citizenship carried significant advantages (for example, for a career). It was an expensive, lengthy, and subjective procedure with an unpredictable outcome.
What did the 2024 reform change?
The new law completely abolished the principle of avoiding multiple citizenships. The key changes are as follows:
Cancellation of the requirement to renounce citizenship
Foreigners naturalizing in Germany now by default retain their original citizenship. Germany no longer requires them to renounce their previous legal status.
Automatic retention for Germans
Germans acquiring citizenship of another country (e.g., the USA, Canada, Australia) no longer automatically lose their German passport. They no longer need to apply for a “Beibehaltungsgenehmigung”.
Reduction of naturalization periods
The reform also accelerated the path to obtaining German citizenship. The standard residency period required for application was reduced from 8 to 5 years. With the presence of “special integration achievements” (for example, a high C1 language level, volunteer work, outstanding professional achievements), naturalization is possible even after 3 years.
Dual citizenship of Germany with other countries
The new law makes Germany’s position clear: it allows dual citizenship. However, it is important to remember that citizenship is a bilateral relationship. Permission from Germany does not mean that the other country automatically agrees with this.
Dual citizenship Germany – USA
This is one of the most frequent requests. Until 2024, this was a complex case. A German obtaining a U.S. passport risked losing their German citizenship without “Beibehaltungsgenehmigung.” An American becoming a German had to go through the procedure of renouncing U.S. citizenship (which is possible but complicated).
The situation has now completely simplified. A U.S. citizen who has lived in Germany for 5 years and meets the requirements can obtain German citizenship and keep their U.S. passport. A German citizen who obtains a Green Card and naturalizes in the U.S. automatically retains their German passport.
Dual citizenship in Germany for Ukrainians
This is an extremely relevant issue in light of recent events. Thousands of Ukrainians who have found refuge or are working in Germany can now apply for a German passport through expedited procedures (in 5 or even 3 years).
Germany’s position: Germany allows Ukrainians to become citizens of the FRG without requiring them to renounce their Ukrainian passport.
The position of Ukraine: Here the situation is more complicated. The Ukrainian law on citizenship adheres to the principle of “single citizenship.” There is no direct prohibition on holding a second passport, but the voluntary acquisition of citizenship of another country is a formal basis for the loss of Ukrainian citizenship (although the mechanism for mass forced deprivation of citizenship is not applied in practice). The reform in Germany removes the barrier from the German side but does not resolve the legal conflict on the part of Ukrainian legislation.
Dual citizenship Germany – Russia
Similar to the situation with Ukraine, Germany, after the 2024 reform, no longer requires Russians naturalizing in the FRG to renounce their Russian citizenship. Russia, in turn, generally takes a loyal stance towards its citizens having second passports (only requiring notification of migration authorities about this).
For a German wondering how to obtain Russian citizenship while living in Germany and not lose their German one, the reform has also become a relief. Previously, it was almost impossible without risking the German status, but now (subject to the requirements of the Russian Federation), the German passport will remain with the applicant.
Tax consequences of dual citizenship in Germany
A common misconception states that having two passports automatically means paying taxes in two countries. This is not entirely true. The key factor for taxation in Germany (and most countries in the world) is not citizenship but tax residency.
Germany applies the principle of taxation based on residency (Ansässigkeit). If you physically reside in Germany (have a “Wohnsitz” — place of residence, or “gewöhnlicher Aufenthalt” — habitual place of stay, for more than 183 days a year), you are considered to have unlimited tax liability (unbeschränkte Steuerpflicht). This means you pay tax to Germany on your entire worldwide income, regardless of whether you hold a passport from Ukraine, the USA, or not. The 2024 citizenship reform has not changed this tax principle in any way.
Exception: USA. The only major country that taxes its citizens regardless of their place of residence is the USA. A US citizen living and working in Munich must pay taxes to Germany and simultaneously file a tax return in the USA.
Agreements on the Avoidance of Double Taxation (DTA)
To prevent people from paying full tax twice, countries enter into Double Taxation Avoidance Agreements (Doppelbesteuerungsabkommen, DTA). Germany has such agreements with most countries, including the USA.
These documents determine which country has the priority right to tax a particular type of income (salary, dividends, rent). As a rule, the tax paid in one country is credited against obligations in another. Nevertheless, for “American Germans,” tax planning and reporting remain significantly more complicated.
Global context: Germany and other countries
By adopting multiple citizenship, Germany joined the majority of Western democracies. Countries such as Canada, the United Kingdom, France, Italy, and Australia have long recognized this status. They view it as a logical consequence of migration and a means of maintaining ties with their diasporas.
At the same time, many major Asian countries (China, India, Japan) still adhere to a strict one-passport policy.
This global gap in approaches forms a complex landscape for investors, entrepreneurs, and highly skilled professionals. In the search for global mobility and asset diversification, many are exploring jurisdictions offering flexible conditions. This list includes various countries that allow dual citizenship, including Vanuatu, which use citizenship programs to attract investments.
Does Germany allow dual citizenship with Vanuatu?
Yes. After the 2024 reform, the answer is unequivocal. If a citizen of Vanuatu meets all the requirements for naturalization in Germany, they can obtain a German passport without renouncing their Vanuatu passport.
Our legal team assists clients at all stages of obtaining citizenship — from verifying grounds and preparing documents to consultations on tax and legal aspects of a second passport.
If German legislation restricts the possibility of retaining citizenship when obtaining a second one, we will help find alternative solutions, including Vanuatu citizenship programs, where dual citizenship is fully allowed and the process takes only a few months.
Contact us to receive professional consultation and choose the safest and most legal way to obtain a second passport — in Germany or beyond.