In the modern world of mobility and global investments, dual citizenship is no longer a rarity. Today, it is a strategic tool for personal and corporate security. More and more countries are recognizing the advantages of openness and allow their citizens to hold a second passport. Dual citizenship opens up opportunities for business, investments, and international activities: you can travel freely, operate in multiple jurisdictions, optimize taxation, and ensure the safety of your family in case of political or economic risks in one of the countries.
However, it is important to understand that the rules for recognizing dual citizenship vary. Therefore, before submitting an application, it is crucial to consult specialists who are familiar with the nuances of the legislation of specific countries. Our team of lawyers specializes in international citizenship and migration law. We analyze your goals, residency, tax status, and offer a strategy that ensures lawful and secure possession of two passports.
Dual citizenship: what is it really?
Dual citizenship is a legal status in which the same individual is simultaneously recognized as a citizen of two (or more) states. This means that a person has rights and obligations toward each of them: they can live, work, and receive social protection in both countries, but they are also required to comply with their laws and fulfill obligations (tax or military).
It is important to understand: not all countries treat dual citizenship the same way. Some states, like the United Kingdom, Canada, or Portugal, officially allow their citizens to have a second passport and recognize both statuses at the legislative level. Others require renouncing the first citizenship when obtaining a new one, except in special cases.
At the same time, there is a subtle but important difference between “second citizenship” and “dual citizenship.” In the first case, a person obtains a passport of another country, but the original country formally does not recognize this fact: legally, it does not acknowledge the second citizenship. In the second case, both states officially recognize the citizen as their own and agree to the existence of a dual legal status.
Such a situation can be convenient but also create difficulties from a legal point of view. For example, tax obligations may arise in both countries, and in the case of a criminal or civil dispute, the issue of jurisdiction becomes especially sensitive. Therefore, when planning to obtain a second citizenship, it is important to take into account the legislation of both countries and assess possible consequences in advance.
Key advantages of a second passport
A second citizenship opens doors to places that usually require dozens of visas and bureaucratic procedures. Holders of a second passport gain the ability to move freely, live, work, and study in different countries without being limited by national boundaries. For citizens of small or developing countries, this is an opportunity to access international opportunities: from business forums and international conferences to prestigious universities and work visas.
For example, passports of Malta, Portugal, or Saint Kitts and Nevis provide visa-free access to more than 150 countries, including the entire Schengen zone, the United Kingdom, and Singapore. Your personal and professional life will no longer depend on visa decisions of consulates.
A second passport is not only freedom of travel but also financial protection. It helps optimize tax burdens, provides access to international banks, and diversifies assets in stable jurisdictions. Citizenship in certain countries ensures complete tax neutrality: no taxes on global income, capital gains, inheritance, or gifts. For international investors, it is a legal and effective tool for tax planning. Additionally, a second passport facilitates access to investment programs, allows conducting business in different countries, and minimizes risks associated with economic or political instability in a single jurisdiction.
Second citizenship is your “Plan B.” In times of political crises, military conflicts, and economic upheavals, it becomes a true insurance policy for your family and capital. Many programs provide access to the best healthcare systems, education, and infrastructure. For example, residents of Caribbean countries with investment programs can not only benefit from a high level of medical care but also travel to Europe for treatment without visa barriers. Second citizenship also guarantees the possibility of safe departure and residence in another country in case of emergencies in your homeland.
In addition to practical advantages, second citizenship opens up new legal and political rights. In some countries, it provides the opportunity to participate in elections, own real estate without restrictions, or engage in entrepreneurial activities on equal terms with citizens. Another important advantage is inheritability. Second citizenship is passed on to children and subsequent generations, ensuring your family an international status and freedom to choose a future place of residence.
Possible Pitfalls of Dual Citizenship
Dual citizenship is an attractive tool for international mobility and asset protection. However, like any legal status, it requires a conscious approach. Along with the advantages, there are aspects that require special attention and are important to know in advance. They cannot be called disadvantages; rather, these are legal and administrative nuances that need to be considered so that the second passport becomes a resource and not a source of problems.
1. Double duties and tax obligations
A holder of two passports is subject to the laws of both countries, which means they bear a double set of obligations. The most striking example is the tax legislation of the USA, where income tax is levied on citizens regardless of their place of residence and employment. Thus, a person with American citizenship and a second passport is required to declare income in all countries and comply with IRS requirements.
Even if the country of second citizenship does not require taxes on income earned abroad (for example, Vanuatu or Saint Kitts and Nevis), it is important to understand that completely different rules may apply in another jurisdiction. Therefore, a professional audit of tax consequences is necessary before obtaining second citizenship.
2. Military duty and service according to the law
Some countries require their citizens to fulfill military service obligations, regardless of holding a second passport. This is relevant for countries with mandatory military service: South Korea, Israel, Turkey, and several European states. In such cases, a dual citizen may be obligated to serve or obtain official exemption. Failure to comply with this requirement can sometimes lead to administrative restrictions, including the inability to obtain documents or cross borders. Legal consultation in advance can help determine whether these requirements apply to you and how to properly arrange exemptions or deferments in accordance with the law.
3. Bureaucratic processes and administrative costs
Second citizenship is often associated with additional formalities: from updating documents and paying fees to participating in identification procedures and passport renewals. Some countries require regular confirmation of status or the provision of information about residence. For example, individuals who have obtained citizenship through investment are required to periodically confirm that they fulfill all the conditions of the program.
It is also important to consider that parallel management of two sets of documents (passports, tax declarations, bank statements) requires systematization, time, and expenses.
4. Restrictions at the level of diplomatic protection
Outside its territory, a state cannot always protect a citizen if they are in the country of their second citizenship. For example, if you have passports from France and Turkey, the French embassy will not be able to intervene in proceedings in Turkey, where you are regarded solely as a Turkish citizen. Therefore, it is important to understand the limitations of consular support in advance and have a strategy of action in case of legal disputes or jurisdictional conflicts.
Ways to obtain a second citizenship
1. Citizenship by Investment Programs
Citizenship by investment programs are the fastest and most transparent way to obtain a second passport. They allow one to become a citizen of another country without the need for long-term residence or renouncing current citizenship. The essence is simple: the applicant makes an investment contribution to the state’s economy in the form of a non-refundable donation, investments in real estate, or business creation, and in return receives a passport.
The most well-known and reliable programs operate in the Caribbean region (Saint Kitts and Nevis, Dominica, Grenada, Saint Lucia, Antigua and Barbuda) and in Vanuatu. Vanuatu offers citizenship by investment starting from $130,000 with processing in just 2–3 months, without requiring visits to the country. Saint Kitts and Nevis is the oldest program in the world, known for its high international reputation. This path is chosen by those who value speed, confidentiality, and global mobility.
2. Jus Soli / Jus Sanguinis
Many countries grant citizenship automatically by place of birth or by parentage. Jus Soli (right of the soil) means that citizenship is granted to a child born on the territory of a state, regardless of the parents’ citizenship. This principle is applied in the USA, Canada, and Brazil. Jus Sanguinis (right of blood) is based on descent: a child receives the citizenship of their parents even if born abroad. This system is used by most European countries, including Italy, Germany, France, and Poland.
3. Through naturalization
Naturalization is a classic path to citizenship, which involves long-term residence in the country and integration into its society. The applicant must reside in the country for a legally established period (usually from 5 to 10 years), have legal resident status, know the language, and comply with the laws. In some countries, it is also required to confirm economic self-sufficiency and knowledge of the culture.
For example, in Portugal or Spain, it is possible to obtain citizenship after several years of legal residence, while the applicant first receives a residence permit, then permanent residence, and only then citizenship. This is the path for those who plan a long-term life and integration into the chosen country.
4. Through marriage or origin
A second citizenship can also be obtained through family ties.
Marriage with a citizen of another country grants the right to a simplified procedure for obtaining a passport, although it is not automatic. For example, in Italy or France, citizenship through marriage can be obtained after several years of living together and proving the family union.
Moreover, many states grant citizenship by descent: if you can prove kinship with ancestors who were citizens of the country. A striking example is Italy, where citizenship can be restored through proven Italian ancestry along the line of ancestors without a residency requirement.
Top countries loyal to dual citizenship in 2025
In 2025, more and more states recognize that dual citizenship is not a threat to national interests but a tool for global integration and economic development. For investors, entrepreneurs, and families, having a second passport has become a strategic decision that provides flexibility, security, and tax efficiency. However, not all countries treat this status equally.
Five attractive European countries
1. Malta
Malta remains one of the most progressive EU countries regarding dual citizenship. The Maltese Citizenship by Naturalisation for Exceptional Services by Direct Investment program allows investors to obtain citizenship in exchange for an economic contribution to the country starting from €600,000, subject to residency requirements. Malta officially permits dual citizenship, and its passport provides visa-free access to over 185 countries, including the USA, Canada, and the entire Schengen Zone. For businesspeople, this is a key to the European market and an opportunity to operate under EU jurisdiction while retaining citizenship of their home country.
2. Portugal
Portugal is one of the few European countries where dual citizenship is allowed and where there is a flexible path to obtaining it through the Golden Visa. This program allows investing in the country’s economy (in real estate, investment funds, or creating a business) and, after five years of residence, applying for citizenship. A Portuguese passport provides visa-free access to 190+ countries, including Canada, Australia, and Japan. At the same time, Portuguese law does not require renouncing your first citizenship. For many investors, this is an optimal combination: access to the EU and a comfortable tax system, especially when obtaining NHR (non-habitual resident) status, which exempts foreign income from taxes.
3. Ireland
Ireland remains one of the most flexible and attractive countries in Europe for obtaining a second citizenship. It allows dual citizenship and offers a unique opportunity – obtaining a passport by descent. If one of your parents or grandparents was Irish, you have the right to register in the Foreign Births Register and obtain citizenship without residing in the country. An Irish passport grants the right to live and work in any EU country, as well as in the United Kingdom under the Common Travel Area agreement.
4. Italy
Italian citizenship by descent is one of the most well-known options for those who want to reconnect with their European roots. Italy officially recognizes dual citizenship, and millions of descendants of Italians around the world have taken advantage of this opportunity. The main advantage of the program is the absence of generational limits, as long as a direct lineage from an Italian ancestor can be proven. For investors, Italy also offers attractive conditions, including investor visas and tax benefits for new residents.
5. United Kingdom
Despite Brexit, the United Kingdom remains one of the most loyal and prestigious jurisdictions for second citizenship. The UK Citizenship Act allows dual citizenship, and many foreigners retain their first passport when obtaining British citizenship.
The main path to it is naturalization after 5 years of residence (or 3 in case of marriage to a citizen). The United Kingdom attracts with its stable legal system, high level of personal freedoms, and the opportunity to live in one of the world’s financial centers.
Five fast and effective programs of the Caribbean and Oceania
1. Vanuatu
Vanuatu is the absolute leader in speed and simplicity of obtaining citizenship. This is the fastest program in the world: from submitting documents to receiving a passport takes only 1–2 months. The country officially allows dual citizenship, does not require renunciation of the first passport, and guarantees a high level of confidentiality. Among the advantages are the absence of taxes on income, inheritance, and capital, making Vanuatu a true tax haven.
The Vanuatu passport provides visa-free access to more than 95 countries, including Hong Kong, Singapore, and Malaysia.
2. Saint Kitts and Nevis
The Citizenship by Investment Program of Saint Kitts and Nevis is the oldest and most reputable in the world (established in 1984). The country allows dual citizenship and offers two investment options: a contribution to the Sustainable Growth Fund or investment in approved real estate. The processing time ranges from 3 to 6 months. A Saint Kitts and Nevis passport provides visa-free access to more than 150 countries, including the United Kingdom and the Schengen Area.
3. Grenada
Citizens of this country can travel to China without a visa – this is a unique advantage among Caribbean programs. Moreover, Grenadian citizenship grants the right to obtain an American E-2 visa, which allows investing and living in the USA. The program is loyal to dual citizenship and provides a passport within 3–4 months with an investment starting from $150,000.
4. Saint Lucia
Saint Lucia offers several investment options: from a contribution to the National Economic Fund to investments in government bonds. The process takes about 3 months. The passport provides access to 145+ countries, including the United Kingdom, Singapore, and Schengen countries.
5. Dominica
Dominica is one of the most reliable and affordable programs in the Caribbean. It has been operating since 1993 and is recognized as one of the most transparent in the world.
The country allows dual citizenship and offers a simple investment structure: a non-refundable contribution starting from $100,000 or participation in approved real estate projects. A Dominica passport allows visa-free travel to 140+ countries, including the Schengen Zone, the United Kingdom, and Hong Kong.
Which countries do not recognize dual citizenship in 2025?
It is important to understand: the refusal to recognize a second citizenship does not always mean the automatic loss of the first. Different countries have different mechanisms: from a complete prohibition to limited allowance with reservations.
1. China
China takes one of the strictest positions in the world regarding second citizenship. The Constitution and the Citizenship Law of the PRC explicitly prohibit dual citizenship. If a Chinese citizen obtains a passport from another country, they automatically lose Chinese citizenship, even without separate notification. Even Chinese citizens living abroad are required to obtain visas to enter China if they have acquired foreign citizenship.
2. India: Ban with elements of flexibility
According to the Citizenship Act of 1955, an Indian citizen who voluntarily obtains a passport of another country automatically loses Indian citizenship. However, India has offered an alternative mechanism – the status of Overseas Citizen of India (OCI). This is not full-fledged citizenship but a special form of permanent residency, granting the right to long-term residence, conducting business, and purchasing property, but without voting rights.
3. United Arab Emirates
The UAE has traditionally adhered to the principle of single citizenship, and until recently, any citizen who obtained a passport from another country automatically lost their Emirati citizenship. However, the situation has begun to change. In 2021, the government introduced amendments allowing dual citizenship in exceptional cases: for investors, scientists, doctors, engineers, and outstanding cultural figures. This decision became part of a strategy to attract talent and capital to the country. Nevertheless, such cases are considered individually, and permission must be granted personally by the ruler of the emirate or federal authorities. For the majority of residents, the rule of single citizenship remains in effect.
4. Japan
The Japanese Nationality Act requires individuals who acquire foreign citizenship to officially renounce their Japanese citizenship within two years. Theoretically, a violation can lead to the loss of citizenship; however, in practice, the authorities take a lenient approach. The Japanese government rarely revokes citizenship if a person does not publicize the possession of a second passport.
The policy regarding dual citizenship is a dynamic area of law, where regulations can change under the influence of global trends, migration, and economic interests. For example, Turkey and Brazil once restricted dual citizenship but later eased the requirements.
Therefore, before obtaining a second passport, it is important to check the current legislation of the specific country and consult with lawyers specializing in international civil law.
Do the USA allow dual citizenship for their citizens?
Yes, the United States officially allows dual citizenship. American legislation does not require citizens to renounce their previous citizenship when obtaining a U.S. passport and, conversely, does not revoke American citizenship if a person voluntarily acquires foreign citizenship.
According to the position of the U.S. Department of State, a person can simultaneously be a citizen of the United States and another country if this does not contradict the laws of the second state. At the same time, an American citizen is required to comply with all U.S. laws, including tax and military obligations. However, it is important to remember that the U.S. tax system is based on the principle of citizenship, not residency. Even while living abroad, a U.S. citizen is obligated to file a tax return annually and, in some cases, pay taxes in the United States.
In addition, upon entry and exit from the USA, a citizen is required to use specifically an American passport, not the passport of their second citizenship. This rule applies to all dual citizens, including those who obtained second citizenship by birth or through investment programs.
With which countries does the USA have dual citizenship?
Unlike some countries, the USA does not enter into formal agreements on dual citizenship. American legislation does not regulate this issue through international treaties but simply recognizes the existence of multiple citizenships. A US citizen can simultaneously be a citizen of another country, provided that the laws of the second country also allow such a possibility.
The possibility of having a second citizenship depends not on the position of the USA but on the laws of another country. American authorities do not require renunciation of existing citizenship and do not annul a U.S. passport when obtaining a new one. Therefore, in practice, U.S. citizens often combine American citizenship with passports from countries in Europe, Latin America, Asia, and Oceania.
How can we help you obtain a second citizenship?
Our team supports clients at all stages of the process: from selecting a program to obtaining a passport. Each client is unique: some strive for travel freedom, others for tax optimization, and some for the protection of family and assets. We start with a detailed analysis of your goals, status, and budget to offer the optimal program in terms of speed, cost, and legal benefits.
We take responsibility for the legal verification of all documents: from confirming sources of income to notarizations and translations. Our task is to make the process as safe and transparent as possible, minimizing the risk of rejection by the state.
We interact directly with accredited agents and government structures of countries participating in CBI programs, which allows our clients to obtain citizenship entirely remotely. All communication, submission, and tracking of documents are carried out through us.
We provide consultations on taxation, financial residency, compliance, and interactions with banks to ensure that your new status does not become a source of risks. All processes are carried out with strict adherence to attorney-client privilege. We guarantee complete confidentiality of the client’s personal data and financial information, ensuring a high level of trust and legal protection.
Contact our team today to discuss which citizenship program best suits your goals. We will develop a personalized strategy, prepare all the documents, and guide you until you receive your second passport.