When you live abroad and become a parent, one question always comes up: What nationality will my child have? In some cases, they may qualify for dual (or even multiple) citizenships, which many see as a long-term asset for a child already growing up as a global citizen. But dual nationality also comes with legal obligations鈥攕ometimes unexpected ones鈥攆or both children and parents. Here's an overview of the rights, responsibilities, and key precautions you should keep in mind.
How can a child acquire dual citizenship abroad?
Everything depends on the laws of the country where your child is born. Here are the three most common scenarios:
By descent (Right of blood)
This is the most widespread case. A child born abroad can acquire the nationality of their parents, provided the countries involved allow transmission of citizenship by descent.
For example, if a French mother and an Australian father living in Dubai have a child, that child will most likely be entitled to both French and Australian nationality.
By birthplace (Right of soil)
Some countries grant citizenship to any child born on their soil, regardless of the parents' nationality. This is the well-known case of the United States and Canada.
Other countries apply a conditional version of birthright citizenship. In Germany, for instance, a child born to foreign parents can obtain German nationality if at least one parent has lived in Germany for five years and holds permanent residency.
France also applies a variation, known as double jus soli (double right of soil). A child born in France to at least one parent who was also born there automatically qualifies for French citizenship, even if the parent is not a French national.
By naturalization
Some states grant nationality after a certain period of residence or through simplified declarations for children. Requirements vary from one country to another but usually involve a minimum stay and some proof of integration, such as intermediate language skills.
What are the benefits of dual citizenship for children?
Dual nationality is often seen as an asset by expat families. Many studies highlight parents who deliberately choose to give birth in countries like the U.S. or Canada to secure an extra passport for their child.
Holding two passports: More freedom of movement
Two passports are more than a travel convenience鈥攖hey're a strategic advantage. Dual citizens can freely enter and leave both countries without visas, and depending on passport agreements, they often gain visa-free access to a wider range of destinations.
For instance, a European passport allows free movement within the Schengen Area, while a Canadian passport provides visa-free entry to much of Asia and the Americas.
Living, studying, and working without restrictions
Forget about lengthy visa processes. Having the nationality of a given country simplifies administrative formalities and grants easier access to social benefits.
It can also improve opportunities in education or the job market. Some schools cap the number of international students they admit, but being a citizen bypasses these quotas.
The financial benefits are also significant. In expensive education systems, citizens often pay far lower fees. In the UK, for example, tuition averages around 拢9,535 per year for domestic students, compared to anywhere from 拢14,000 to 拢70,000 for international students.
A safety net in times of crisis
Dual citizenship provides a legal fallback option in times of political, economic, or health crises. Having two nationalities means you can relocate, access healthcare, continue your career or studies, or simply seek a more stable environment in your other country of citizenship.
Property ownership
Dual nationals often find it easier to buy property.
In Thailand, for example, foreigners can only purchase real estate under strict conditions, such as through condominium quotas. In Switzerland, non-EU citizens need government approval to acquire property. None of these restrictions apply if you hold the country's passport.
What are the obligations of dual citizens?
Dual citizenship isn't just a bundle of rights; it also comes with duties. Children are full citizens in both of their countries, with all the obligations that entails, even if they don't live there. Tax and military requirements are among the most common鈥攁nd sometimes surprising鈥攔esponsibilities.
Military service
Many countries no longer enforce compulsory service, but not all. Israel, for instance, requires all citizens to serve at age 18. Dual nationality does not exempt you, although special arrangements may exist for residents abroad.
Things get complicated in overlapping cases. Imagine an Israeli-American required to serve in Israel: U.S. law prohibits American citizens from engaging in foreign military service, creating potential conflicts.
Tax obligations
Taxes can follow you across borders. Some countries require all citizens鈥攊ncluding minors鈥攖o declare income, regardless of residence.
The United States is the most famous example. As long as your child holds U.S. nationality, you must file tax returns with the IRS鈥攅ven if your family has no economic ties to the U.S.
For instance, an American child living in France could be taxed if their annual income (from investments or other sources) exceeds $12,950.
What parents should watch out for
Explicit declarations of citizenship
Don't assume dual nationality happens automatically. Some countries require formal declarations.
For example, a child born abroad to German parents will only acquire German nationality if the parents file an explicit declaration at the local German consulate before the child's first birthday.
Passport rules: Entry and exit requirements
Dual nationals may be subject to strict passport rules. Take the case of a Spanish-American child living in Spain but traveling often to the U.S. If the child's American passport expires, U.S. authorities will not allow entry on a Spanish passport. By law, American citizens鈥攊ncluding dual nationals鈥攎ust use a U.S. passport to enter and leave the country.
Immigration controls can also be tougher when multiple nationalities are involved. Always carry a parental authorization to travel, especially in cases of separated binational couples.
When parent and child don't share a nationality
If a parent does not hold the same nationality as their child, everyday formalities鈥攕uch as education, healthcare, or legal procedures鈥攃an become more complicated abroad.
In some countries, only the parent who shares the child's nationality is legally recognized as the primary guardian.
Divorce or custody disputes can also be affected: the applicable law may depend on which nationality is given precedence.
Mandatory choice of citizenship
Finally, remember that some countries only allow dual citizenship for minors. Once your child reaches adulthood, they may be required to choose.Japan, for instance, requires dual nationals to select one citizenship before the age of 22. Failure to choose can result in the automatic loss of Japanese nationality.Such a decision can be emotionally difficult and, if delayed, may even leave the child in legal limbo.
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