Christian H. Kälin

Global Residence and Citizenship Handbook


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Holders of such documents run a serious risk of exposure, arrest and deportation. Even in those countries where the law gives the President, Prime Minister or other government ministers relative discretion regarding the granting of citizenship, if any payments are involved, these are bribes – a crime in almost every country. Often the result is a revocation of previously granted citizenship and passports, for example after a change of government. Persons who have acquired documents this way are also frequently blackmailed and forced to pay further ‘fees’ later on.45 It is therefore crucial that citizenship is obtained based upon specific provisions in the law and clear, official procedures.

      A related criterion is that the granting of citizenship and the passports issued in conjunction therewith have to be recognized by other countries. If full citizenship has been granted based on the legal provisions of a country, it will normally be recognized by other countries. However, if only non-citizens passports are granted, generally this is not a good option. One example is Panama where a (legal) non-citizens passport under the retiree residence program can be acquired.

      Other important points to consider when intending to become a citizen of choice include the geographic location of the country, the official language, political and economic stability, the legal system, the banking and business environment, visa-free travel possibilities for passport holders of that country, the reputation of the country and the passport, and of course initial and future overall costs.

      You will also need to consider restrictions on dual citizenship. Some countries do not allow you to hold any other citizenship besides theirs. About half of the world’s countries allow dual nationality, and the other half does not allow you to be a citizen of another country at the same time. Among those countries which do not allow dual nationality, various degrees of strictness can be observed, but often the acquisition of another citizenship without first obtaining a formal permission (which may or may not be obtainable) leads to the automatic loss of one’s current citizenship. Therefore, one needs to carefully check the legal situation in the home country with regard to dual citizenship, prior to taking any steps to acquire another citizenship.

      The following is an overview of citizenship regulations in selected countries.46

      Among others, the following countries allow the acquisition of another citizenship:

Antigua and BarbudaAustralia
Austria47Bangladesh
BarbadosBelgium
BelizeBrazil
BulgariaCanada
ChileColombia
CroatiaCyprus
DominicaDominican Republic
El SalvadorEgypt48
FinlandFrance
Germany49Greece
GrenadaHungary
IcelandIran
IraqIreland
IsraelItaly
JordanLatvia
LebanonLithuania
MacedoniaMalta
MexicoMontenegro
New ZealandPakistan50
PhilippinesRomania
RussiaSerbia
Spain51Sri Lanka
St. Kitts and NevisSt. Lucia
SwedenSwitzerland
SyriaUnited Kingdom
United States of AmericaVietnam
Western Samoa

      On the other hand, countries which do not allow the acquisition of another citizenship include the following:

AzerbaijanBrunei
ChinaCzech Republic52
DenmarkEcuador
FijiIndia53
IndonesiaJapan
KazakhstanKenya
KiribatiKuwait
MalaysiaMauritius
MyanmarNepal
NorwayPapua New Guinea
PeruPoland
PortugalSaudi Arabia54
Solomon IslandsSouth Africa55
SingaporeTurkey
Spain56Venezuela
Ukraine

      One of the most important criteria specific to citizenship is of course the overall reputation of the country and its passport. It is futile to obtain a second passport if the country has a poor reputation at a regional and international level, and therefore its passport is not well regarded and does not afford much visa-free travel, or causes suspicion at international borders.

      20 Wallerstein (1974) and Zolberg (1981)

      21 See Ong (1999)

      22 See for example Torpey (2000), Lloyd (2005), Joppke (2010), Hokema (2002)

      23 See The Henley & Partners Visa Restrictions Index (HVRI); www.henleyglobal.com/international-visa-restrictions/

      24 This can happen even to citizens of small and generally neutral countries, as Danish citizens experienced following the publication of Mohammed cartoons in the Jyllands-Posten newspaper in Denmark on 30 September 2005

      25 The Economist, 19 February 2013 “Tourist visas: You’re not welcome”

      26 For a good discussion of the differences between residence and citizenship statuses, see Joppke (2010)

      27 See Betten (1998) and Chapter 3 in this book

      28 See Ong (1999)

      29 For example in St. Kitts and Nevis

      30 Although some countries, such as the UK and New Zealand, have introduced limits to the passing on of citizenship infinitely through blood line if not also remaining a resident

      31 See Hokema (2002) and Hansen/Weil (2001) on multiple citizenship

      32 Some countries do not even allow you to give up your citizenship unless you have another one. For a good discussion of statelessness, see Stiller (2011)

      33 For example in China, Malaysia, the UAE and many other countries, there are minority groups which are resident there but are prevented from acquiring citizenship of the country they live in

      34 In some Swiss Cantons for example, you have to pass an “integration” test, which means that you may need to learn some Swiss history and other things deemed useful to qualify for the privilege of applying for Swiss citizenship. In some Asian countries, if you are not of a particular ethnic origin, your chances of ever being granted citizenship are close to zero. In most Muslim countries you need not apply if you are not Muslim

      35 See the chapter by Professor Weil for further information on this

      36 Ireland for example

      37 For an extensive overview see Bauman (2009) and www.henleyglobal.com

      38 Henley & Partners constantly monitor and evaluate residence and citizenship programs around the world against a number of criteria

      39 For an in-depth discussion of these options see Part IV

      40 For example, Bulgaria, Cape Verde, Grenada, Nauru, the Seychelles, most South American countries, and others

      41 Montenegro, for example, granted citizenship to the controversial former Thai Prime Minister Thaksin Shinawatra on the basis of a mere promise to invest in the country

      42 Panama, under its retiree residence program

      43 Tonga and a couple of African countries

      44 For more information see the website of the Ministry of Interior of Iceland http://eng.innanrikisraduneyti.is/laws-and-regulations/english/citizenship/nr/27049

      45 As has been the case in Costa Rica and other Latin American countries for many years

      46 The information is based on the author’s