# Regarding Dual-Citizens



## Zarcero

*How are bona fide dual-citizens regarded in your respective countries?*

By _bona fide_ I mean a citizen who is considered a citizen of both countries at birth, not a citizen who moves from one country to another and then takes up a second citizenship through nationalization/naturalization.


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## Macunaíma

Here, anyone born in Brazilian territory is considered Brazilian, and _only_ Brazilian for all intents and purposes, unless they are born inside the territory but outside the country's jurisdiction, as is the case with children born to foreign diplomats or, say, aboard a foreign ship stationed in a Brazilian port (not that I've heard of any such case). When they come of age, they may _relinquish their Brazilian citizenship (*)_ and embrace another one if they wish. But until then, they are Brazilians and treated as such. 

Dual citizenship is common in Brazil. Even our First Lady and our Finance Minister (who is Italian born) are dual citizens. We don't see anything wrong with that.

* _I've had a look at the Brazilian Foreign Affairs Ministry website and learned that a Brazilian person only loses his or her Brazilian citizenship if he or she adopts another nationality by marriage to a foreigner. Dual citizenships are allowed for people who are descended from immigrants whose country of origin recognize them as nationals (jus sanguinis) or children of Brazilian parents who were born in countries which, like Brazil, recognize them as nationals because they were born within their territories (jus solis). _


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## Frank78

In Germany every person who can prove that he/she is of German descent can apply for German citizenship, it doesn´t matter where you were born (even if you live in fifth generation in another country). If both parents are German the child gets automatically German citizenship, no matter where the child is born.

If one parent is German and the other one foreign (or if the child is born in a country like Brazil or the US)  then the child must decide which citizenship he/she wants at the age of 18. We do not allow dual-citizenships.


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## Carfer

Portuguese law allows dual-citizenship with the proviso that the citizen who is simultaneously national of another country can not claim this other nationality to evade the Portuguese law. Therefore, the fact that someone may have another citizenship other than the Portuguese one is quite irrelevant under a legal standpoint. Likewise the average citizen doesn't care if his fellow countryman has a dual citizenship or not. I think most people regard dual-citizenship as quite a natural thing, Portugal having been a emigration country until quite recently, so people are used to their kin having another nationality. When the situation reversed around thirty years ago and Portugal became an immigration country, the Portuguese were prepared to accept the fact that the newcomer's children would be Portuguese citizens as well as citizens of their parent's country.


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## Zarcero

But how are dual-citizens treated culturally, not just legally?  As an example, are they considered "outlanders" to both countries?  What have your experiences been, either as a dual-citizen yourself or in what you have observed in dual-citizens that are _jus sanguinis/solis_?

( *Macunaíma*, thanks for the terminology)


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## mirx

Zarcero said:


> But how are dual-citizens treated culturally, not just legally?  As an example, are they considered "outlanders" to both countries?  What have your experiences been, either as a dual-citizen yourself or in what you have observed in dual-citizens that are _jus sanguinis/solis_?
> 
> ( *Macunaíma*, thanks for the terminology)



Legally I think Mexico is the same as Brazil. 
Culturally, and I think I speak for most Mexicans here, we regard as "Mexican" anyone grown in our culture, lifestyles, traditions, gastronomy, etc., regarldess of where you were born.

So for example, Spanish, Gringo or kids from Central America (our major sources of immigration) born in Spain, USA or any country in Central America respectively; but who were raised, went to school and lived  always in Meixco, will be most definetely considered Mexican. On the other hand, kids who are born in Mexico but raised in a different country will be treated as foreigners, our clearest example being the Mexican-american comunity.


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## sokol

Zarcero said:


> But how are dual-citizens treated culturally, not just legally?  As an example, are they considered "outlanders" to both countries?  What have your experiences been, either as a dual-citizen yourself or in what you have observed in dual-citizens that are _jus sanguinis/solis_?


Legally, Austrian citizenship allows dual citizenship only exceptionally - but they're not ruled out like in Germany (and also Austria has a "standard" citizenship law which isn't based on any ancestry of German mother tongue like is the case in Germany).

Culturally, dual citizens (those born and raised here) are just considered as Austrians, they aren't considered to be non-natives - simple as that.

Of course in some cases people still will know that someone is of foreign descent, e. g. if they have a name which couldn't possibly be "native" (Turkish for example, or Chinese; Slavic names however aren't easily recognisable as non-native as a great many "native" Austrian names are Slavic), if they wear a scarf, if they are of a different race, if they still speak with a foreign accent etc. Those that are recognisable as of foreign descent might be subject to discrimination just as if they weren't naturalised Austrian citizens; however most of those aren't dual-citizens, they're usually either foreign or Austrian citizens. (As said, dual citizenship only is granted in rather special cases.)


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## Frank78

sokol said:


> Legally, Austrian citizenship allows dual citizenship only exceptionally - but they're not ruled out like in Germany (and also Austria has a "standard" citizenship law which isn't based on any ancestry of German mother tongue like is the case in Germany).
> 
> Culturally, dual citizens (those born and raised here) are just considered as Austrians, they aren't considered to be non-natives - simple as that.
> 
> Of course in some cases people still will know that someone is of foreign descent, e. g. if they have a name which couldn't possibly be "native" (Turkish for example, or Chinese; Slavic names however aren't easily recognisable as non-native as a great many "native" Austrian names are Slavic), if they wear a scarf, if they are of a different race, if they still speak with a foreign accent etc. Those that are recognisable as of foreign descent might be subject to discrimination just as if they weren't naturalised Austrian citizens; however most of those aren't dual-citizens, they're usually either foreign or Austrian citizens. (As said, dual citizenship only is granted in rather special cases.)



We´ve got a few exceptions, too. Mostly regarding other EU-citizens. If you´re interested read StAG § 12


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## Macunaíma

Zarcero said:


> But how are dual-citizens treated culturally, not just legally? As an example, are they considered "outlanders" to both countries? What have your experiences been, either as a dual-citizen yourself or in what you have observed in dual-citizens that are _jus sanguinis/solis_?


 
Dual citizens in Brazil are seen as normal Brazilian citizens. We don't see them any differently. Because Brazil received a massive number of immigrants in past generations, especially from the late 19th century to the mid 20th, and most of these immigrants came from coutries where citizenship is passed on down the generations (e.g. Italy, Japan and Germany) *, many Brazilians are now either dual citizens or eligible for dual citizenship. They are legally considered Brazilian and culturally _even more so_. As Mirx said about Mexico, we consider Brazilian anyone who speaks our language and shares our lifestyle (or _doesn't_ share our lifestyle, for that matter), regardless of their country of origin or if they are dual citizens or not (which is irrelevant anyway).

* As far as I know, Portugal only recognizes as citizens people born to Portuguese _parents_, i.e., the first generation. Grandchildren or great-grandchildren of Portuguese emmigrants are not eligible. Otherwise, a huge fraction of the Brazilian population would be potential Portuguese-Brazilian citizens...


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## Carfer

Macunaíma said:


> As far as I know, Portugal only recognizes as citizens people born to Portuguese _parents_, i.e., the first generation. Grandchildren or great-grandchildren of Portuguese emmigrants are not eligible. Otherwise, a huge fraction of the Brazilian population would be potential Portuguese-Brazilian citizens...


 
That's right, and only if the parents register the child as a Portuguese national in the nearest consulate. Nonetheless, the child may live all his/her life outside Portugal and have another nationality that it doesn't deter him/her from still being legally Portuguese. 
More to the point, if the emigrant child returns to Portugal after a long absence, he/she would for sure be viewed as a foreigner, although legally Portuguese. As I said in my previous post as a rule the dual citizenship is irrelevant regarding the way the Portuguese people view dual-citizens. A Portuguese citizen that doesn't speak the language or doesn't act according to our cultural values and lifestyle will be viewed as a foreigner despite him/her being a Portuguese national or a dual-citizen (*). 
On the other hand, a foreign national who speaks correct Portuguese and acts like a Portuguese person and doesn't detract from our way of life, will be almost certainly considered a Portuguese. No one cares very much about the colour of your passport or if you have one or two or three. Actually, I think that the core of this question is not dual-citizenship, which is a matter of legal status that most people tend to overlook, but the way that people that were born or have lived a long time abroad or belong to families of foreign origin interact with the citizens of the country where they presently live and how they are viewed by these ones. 

(*) There's a case in point: the English families which established in the Douro Valley in the eighteen century and which have ever since dominated the Port wine trade. They are bi-nationals, and despite most of them speaking correct Portuguese and not living in seclusion, they are usually educated in England, keep their traditions, consider themselves British and... consequently are in a way viewed as British, but not definitely as absolute foreigners because their close ties with Portugal prevent us from seeing them as total aliens.


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## Sepia

Frank78 said:


> We´ve got a few exceptions, too. Mostly regarding other EU-citizens. If you´re interested read StAG § 12




??????!!!!!!! Where do you see exeptions regarding EU-citizens in StAG § 12?

There are exceptions that come into effect when e.g. Turkish citizens apply for German citizenship because they cannot give up their Turkish citizenship, according to Turkish law. 



§ 25 is interesting: A German citizen looses his German citizenship once he is granted citizenship in another country. In practical terms this means: When a German moves to Canada or the USA, eventually becomes a citizen there, he keeps his mouth shut about it when talking to German authorities.


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## Frank78

Sepia said:


> ??????!!!!!!! Where do you see exeptions regarding EU-citizens in StAG § 12?



§12 Abs. 2 

"Von der Voraussetzung des § 10 Abs. 1 Satz 1 Nr. 4* wird ferner abgesehen, wenn der Ausländer die Staatsangehörigkeit eines anderen Mitgliedstaates der Europäischen Union oder der Schweiz besitzt"

*says: "4. seine bisherige Staatsangehörigkeit aufgibt oder verliert"


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## Zarcero

Did German law change over the last few decades regarding this?

1.  I thought at one time rejecting German citizenship was not an option, and that even if one left Germany and nationalized to another country, that one would still be considered German when back on German soil.

2.  I also thought that children born of German parents abroad, were automatically considered citizens of Germany whether they liked it or not, and hence would be considered so if visiting German soil.


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## Dr. Quizá

Zarcero said:


> *How are bona fide dual-citizens regarded in your respective countries?*
> 
> By _bona fide_ I mean a citizen who is considered a citizen of both countries at birth, not a citizen who moves from one country to another and then takes up a second citizenship through nationalization/naturalization.



They are seen as an average guy who anecdotally has a foreign parent.


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## Frank78

Zarcero said:


> Did German law change over the last few decades regarding this?
> 
> 1.  I thought at one time rejecting German citizenship was not an option, and that even if one left Germany and nationalized to another country, that one would still be considered German when back on German soil.


 
Yes, Germans can keep there citizenship when applying for another country´s citizenship under certain circumstances.  So called "Beibehaltungsgenehmigung".
You have to fullfil both points:
1. still a connection to Germany (close relatives or property here)
2. dual-citizenship has a signifcant advantage in your situation



Zarcero said:


> 2.  I also thought that children born of German parents abroad, were automatically considered citizens of Germany whether they liked it or not, and hence would be considered so if visiting German soil.



Correct. Well if they are born in the US, they have a dual citizenship until they become adults and must decide.


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## Sepia

Frank78 said:


> §12 Abs. 2
> 
> "Von der Voraussetzung des § 10 Abs. 1 Satz 1 Nr. 4* wird ferner abgesehen, wenn der Ausländer die Staatsangehörigkeit eines anderen Mitgliedstaates der Europäischen Union oder der Schweiz besitzt"
> 
> *says: "4. seine bisherige Staatsangehörigkeit aufgibt oder verliert"


 

OK, sure, but that does not provide any exception to the rules concerning dual citizenship.

On the contrary: There is a document from the EU Commision saying that it should generally be avoided by the member states allowing dual citizenship. When an adult person applies for citizenship the procedure is that he leaves his passport with the authority processing his case and they inform the ministry of foreign affairs in his country of origin that he is now giving up his citizenship.


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## Frank78

Sepia said:


> OK, sure, but that does not provide any exception to the rules concerning dual citizenship.



Huh It does. A Brit appling for German citizenship can now keep his British citizenship, believe me. 

That´s one of the requirements to get German citizenship: "seine bisherige Staatsangehörigkeit aufgibt oder verliert" (to give up your current citizenship) but now if you are from the EU or Switzerland this does NOT apply to you.

"*Von der Voraussetzung* des § 10 Abs. 1 Satz 1 Nr. 4 wird ferner *abgesehen*, wenn der Ausländer die Staatsangehörigkeit eines anderen Mitgliedstaates der Europäischen Union oder der Schweiz besitzt"


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## Sepia

Frank78 said:


> Huh It does. A Brit appling for German citizenship can now keep his British citizenship, believe me.
> 
> That´s one of the requirements to get German citizenship: "seine bisherige Staatsangehörigkeit aufgibt oder verliert" (to give up your current citizenship) but now if you are from the EU or Switzerland this does NOT apply to you.
> 
> "*Von der Voraussetzung* des § 10 Abs. 1 Satz 1 Nr. 4 wird ferner *abgesehen*, wenn der Ausländer die Staatsangehörigkeit eines anderen Mitgliedstaates der Europäischen Union oder der Schweiz besitzt"


 
Officially, by German procedures or because the British find it OK (and don't cancel the British citizenship after all) or because there exists an agreement on this point between the UK and Germany? Three different ball games ...


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## Frank78

Am I talking Chinese or what? 

It´s German law, so it´s a German procedure.
Of course, the original country must allow dual citizenship (As far as I know Britain allows it).

Mutual agreements between two countries are, by the way, another exception.


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## Abu Rashid

> *How are bona fide dual-citizens regarded in your respective countries?*


*

*A large % of the population of my country (Australia) has parents not born here, so there's many people with dual citizenship (from birth). The law recognises and accepts this dual citizenship, but sometimes, especially lately, it's been used to question the loyalty of some to the country.



> As an example, are they considered "outlanders" to both countries?



They might not be considered outlanders necessarily, but they are definitely noted as being foreign to some extent, in both countries. My wife is a dual citizen of Egypt/Australia, and here she is considered Egyptian, and in Egypt she is considered Australian.


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## Zarcero

Abu Rashid said:


> ...My wife is a dual citizen of Egypt/Australia, and here she is considered Egyptian, and in Egypt she is considered Australian.



Yes, this is kind of my experience as well.


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## Sepia

Frank78 said:


> Am I talking Chinese or what?
> 
> It´s German law, so it´s a German procedure.
> Of course, the original country must allow dual citizenship (As far as I know Britain allows it).
> 
> Mutual agreements between two countries are, by the way, another exception.


 

Yes, it is German law - and it says it is possible when based on some kind of treaty between Germany and another country. There isn't an overall agreement that dual citizenship is accepted within the EU so it would have to be a treaty between  the UK and Germany - so that is the reason why I am asking. 

I know Britain allows it. I know various people with dual - and one even with triple citizenship - where only one of the "participating" countries allows it. 

So if you can answer it OK - if not you definitely have no reason to treat me as if I were stupid.


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## Frank78

There are 2 seperate distinguishable cases

1. Germany grants every EU and Swiss citizen dual-citzishenship. It is not of concern here if the other country allows it because countries which do not allow it are already excluded.  That´s a law and not an interstate agreement so a completly domestic matter.
There´s a rather old verdict (I think around the year 2000) of a Bavarian court which would exclude EU-citizen from Luxemburg, Austria and Sweden because they wouldn´t allow Germans (or any other EU citizizens) to keep their native citizenship if applying there for the other citizenship. I don´t know if it´s still valid.

2. Further dual citizenship is allowed if German and another country have an agreement. There´s no need of such an agreement for the states in case 1 since they are already regulated by law.

P.S.: It wasn´t my intention to offend you. It just seems too clear to me.


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## HUMBERT0

Many in my neck of the woods have Dual-Citizens, some live here and work on the US, and it’s neither rare nor frowned upon, at least on this side of the fence. Our constitution does allow Dual-Citizenship.


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## Zarcero

HUMBERT0 said:


> ...Our constitution does allow Dual-Citizenship...


  I believe that is recent, correct?


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## Abu Rashid

Funnily in my country dual citizenship was always allowed for non-Australians taking up Australian citizenship, but any Australian who actively sought a second citizenship would be instantly stripped of Australian citizenship, and deported if present in the country.

This happened to quite a lot of people, even kids who'd grown up all their life here, suddenly found themselves in countries they'd never visited and didn't even speak the language, simply because their parents for instance had sought a second citizenship, and so now the entire family was deported and dis-Australian-ised.


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## HUMBERT0

Zarcero said:


> I believe that is recent, correct?


Yes, a few years back you had to choose, not anymore. I you accept another citizenship you do not lose Mexican nationality.


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## trbl

Frank78 said:


> In Germany every person who can prove that he/she is of German descent can apply for German citizenship, it doesn´t matter where you were born (even if you live in fifth generation in another country). If both parents are German the child gets automatically German citizenship, no matter where the child is born.
> 
> If one parent is German and the other one foreign (or if the child is born in a country like Brazil or the US) then the child must decide which citizenship he/she wants at the age of 18. We do not allow dual-citizenships.



This is not correct. Only children who acquire German citizenship by birth on the basis of being born to foreign parents who have been legal residents for at least 8 years (the so called _Optionsmodell_) must opt for either German or their parents' citizenship at 23.

A child born in the United States (or any other country that grants citizenship automatically to any person born on its soil) to German parents may keep both citizenships. The same applies if one parent is German and the other is from a country that grants citizenship automatically on the basis of ius sanguinis. Thus, if a child is born in the United States to a German mother and, say, a Mexican or Japanese father, they may keep all three citizenships. A person must give up their German citizenship only if they voluntarily and actively acquire the citizenship of another country.

Also, the Right of Return only applies to officially recognized refugees from Eastern Europe and the former Soviet Union. A fifth generation German-Canadian or German-Brazilian is not entitled to German citizenship.


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## Sepia

trbl said:


> This is not correct. Only children who acquire German citizenship by birth on the basis of being born to foreign parents who have been legal residents for at least 8 years (the so called _Optionsmodell_) must opt for either German or their parents' citizenship at 23.
> 
> A child born in the United States (or any other country that grants citizenship automatically to any person born on its soil) to German parents may keep both citizenships. The same applies if one parent is German and the other is from a country that grants citizenship automatically on the basis of ius sanguinis. Thus, if a child is born in the United States to a German mother and, say, a Mexican or Japanese father, they may keep all three citizenships. A person must give up their German citizenship only if they voluntarily and actively acquire the citizenship of another country.
> 
> Also, the Right of Return only applies to officially recognized refugees from Eastern Europe and the former Soviet Union. A fifth generation German-Canadian or German-Brazilian is not entitled to German citizenship.


 
True. We had that changed. Just as it is not sufficient any more to have been a mercenary serving the Nazis - or to have a father that did.

I know it was not called "mercenary" in the law, but basically it was the same thing.


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