Dual Nationality: Which Countries Permit It and Which Don't

Dual nationality — holding citizenship of two or more countries simultaneously — is the foundation of modern passport portfolio strategy. Yet the rules governing it are deeply inconsistent across jurisdictions, poorly understood even by well-travelled professionals, and subject to quiet but significant change. Germany's 2024 liberalisation removed one of Europe's last major dual nationality obstacles; new restrictions in other jurisdictions arrive with little fanfare.

This guide maps the current landscape of dual nationality permissions as of 2026 — which countries allow it freely, which prohibit it, and the nuanced "conditional permission" category that sits between the two.

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Countries That Permit Dual Nationality Freely

The following major jurisdictions impose no legal restriction on their citizens holding one or more additional citizenships. Naturalisation in these countries does not require you to renounce your existing passport, and acquiring another nationality whilst holding citizenship of these countries does not trigger automatic loss.

United Kingdom The UK has permitted dual and multiple nationality without restriction since the British Nationality Act 1981. There is no requirement to disclose secondary citizenships to the Home Office, and no adverse consequences of holding multiple passports. However, applicants for certain sensitive government roles (security-cleared positions, MI5, MI6, GCHQ roles) may face restrictions based on foreign citizenship.

United States The US does not formally recognise dual nationality in statute, but neither does it prevent it in practice. The State Department acknowledges that dual nationality exists and that US law does not require Americans to choose. US citizens can naturalise elsewhere (though they must take care about the intent question — see below) and can acquire US citizenship without renouncing existing citizenship in most cases.

France France permits dual and multiple nationality and has done so for decades. French citizens may hold any number of other citizenships without penalty, and naturalisation as French does not require renunciation of other passports.

Germany (since June 2024) Germany historically required renunciation of existing citizenship as a condition of naturalisation, with limited exceptions (EU and Swiss citizens, recognised hardship cases). The reform enacted under the StARModG, which took effect on 27 June 2024, now permits retention of existing citizenships in most cases. Germany-born children of foreign parents can now more easily hold both German citizenship and their parents' citizenship. This was a significant policy shift that opened the pathway for many long-term residents who had been unwilling to renounce their original nationality.

Ireland Ireland permits dual nationality. Irish citizenship by descent (through a grandparent born on the island of Ireland) is particularly sought after for British nationals seeking EU citizenship post-Brexit — and the process can be completed without relinquishing British citizenship.

Italy Italy permits multiple nationality. Italian citizenship by descent (the jus sanguinis route) can in theory be claimed for ancestors going back many generations. Italy does not require renunciation.

Portugal Portugal permits dual nationality. This is relevant for those acquiring Portuguese citizenship after five years of residence, including via the Golden Visa pathway once the residency threshold is met.

Spain Spain is a nuanced case. Spain generally permits dual nationality for nationals of Latin American countries, Andorra, the Philippines, Equatorial Guinea, and Portugal under bilateral treaties. For nationals of other countries (including the UK), Spanish naturalisation requires renunciation of the prior nationality, though the renunciation is somewhat procedural and Spain does not formally verify whether the other country has complied with it. UK nationals who "renounce" British citizenship in order to naturalise as Spanish technically lose British citizenship under UK law — except that Spain does not control UK nationality, so some individuals navigate this ambiguously. Take specialist advice.

Canada, Australia, New Zealand All three permit dual nationality, as discussed in our guides on those specific jurisdictions.

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Countries That Prohibit Dual Nationality

The following states do not recognise dual nationality and treat naturalisation in another country as an automatic forfeiture of original citizenship. This has practical consequences for property rights, inheritance, business ownership, and travel to the home country.

China The People's Republic of China does not recognise dual nationality. Upon naturalising as a citizen of another country, a Chinese national automatically ceases to be a Chinese citizen under Chinese law. The Chinese government does not recognise the second passport for travel to China — Chinese-born individuals who naturalise elsewhere may be required to travel to China on their Chinese passport and may face difficulties accessing Chinese banking, property, or inheritance rights. This creates acute complexity for Chinese nationals naturalising in countries with whom China has no dual nationality agreement (effectively all countries).

India India's Citizenship Act 1955 does not permit dual nationality. An Indian citizen who voluntarily acquires the citizenship of another country automatically ceases to be an Indian citizen from the date of that acquisition. India does offer the Overseas Citizen of India (OCI) card, which is sometimes described as "dual citizenship" but is not. OCI provides a multi-entry, multi-purpose lifelong visa for foreign nationals of Indian origin, along with some property and business rights in India, but does not confer Indian citizenship, voting rights, or the ability to hold Indian public office.

Japan Japan does not permit dual nationality. Japanese nationals who acquire another citizenship are required to declare their choice of citizenship and renounce the one they are not retaining. For Japanese children born abroad who acquire another citizenship at birth (e.g., jus soli in the US or Canada), a declaration of chosen nationality is required upon reaching adulthood. Enforcement of this requirement has historically been inconsistent, but the Japanese government has been increasing its administrative scrutiny in recent years.

Singapore Singapore does not permit dual nationality for citizens. A Singaporean citizen who acquires another citizenship must renounce Singaporean citizenship or face the consequences, which can include loss of the Singaporean passport. This is enforced actively. Notably, Singapore permanent residents (PR) who are not yet citizens are not restricted in holding their original nationality.

Saudi Arabia Saudi Arabia does not recognise dual nationality in general, though the rules have been subject to change, and there are exceptions for the children of Saudi women married to foreigners. The country's citizenship and residency framework is evolving (notably with the new Premium Residency scheme), and advice should be taken on the current rules for specific situations.

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Conditional Dual Nationality

Several jurisdictions occupy a middle ground: they permit dual nationality under specific circumstances but not universally.

Netherlands The Netherlands generally does not permit dual nationality, but allows it in a growing number of cases: naturalisation after long-term residence in the Netherlands (where renouncing the original passport would cause undue hardship), children who hold multiple citizenships from birth or adoption (who are not required to give up either), and marriage to or registered partnership with a Dutch citizen. The rules have been debated in the Dutch parliament and may be further liberalised.

Austria Austria prohibits dual nationality in most cases, requiring renunciation upon naturalisation. Exceptions exist for those who would suffer significant disadvantage from renunciation (e.g., significant property rights would be lost), and for those qualifying for Austrian citizenship by descent where continuous citizenship is recognised.

South Korea South Korea historically required citizens to choose one nationality, but has gradually expanded the circumstances in which dual nationality is permitted: those who acquire Korean citizenship by birth in a dual nationality situation may apply to retain both under certain conditions; overseas adoptees; and those who have made distinguished contributions to Korea. Standard naturalisations still require renunciation.

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What Happens When You Naturalise Abroad

When you naturalise in a country that permits dual nationality, your original citizenship is generally unaffected from the perspective of your original country — unless that country treats voluntary acquisition of another nationality as grounds for automatic loss, as China, India, Japan, and Singapore do.

For nationals of countries that do not restrict dual nationality, naturalising abroad simply adds a passport. The practical consequences include:

• Additional travel document options (useful for visa-restricted travel)
• The ability to reside and work in two or more countries without visa restrictions
• Estate planning implications where different succession laws apply to different citizenship statuses
• Potential tax treaty implications (see our guide on tax treaties and citizenship interaction)

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The US Intent Exception

US law (8 USC § 1481) provides that a US citizen can voluntarily relinquish citizenship by performing a potentially expatriating act — including naturalising in a foreign state — with the intent of relinquishing US citizenship. Without that intent, naturalisation in another country does not cause loss of US citizenship.

The courts and the State Department have established a strong presumption that Americans naturalising elsewhere do not intend to relinquish citizenship, and it is very difficult for the government to overcome that presumption. In practice, the vast majority of Americans who naturalise elsewhere retain their US citizenship without any formal action. However, the voluntary relinquishment rules are complex and have tax implications (see our guide on American citizenship renunciation) — take specialist US counsel if you are considering the issue.

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Practical Recommendations

For HNW individuals building or optimising a passport portfolio:

1. Always verify the dual nationality rules of your country of origin before naturalising elsewhere. Do not assume that because your destination country permits dual nationality, your original country does too.

2. Check the rules in your children's countries of citizenship if they hold multiple. Japan and South Korea require a choice upon adulthood; other jurisdictions have time limits or declaration requirements.

3. Verify current rules — they change. Germany's liberalisation was significant; other jurisdictions are reviewing their positions. Advice based on the position three or four years ago may be outdated.

4. Tax consequences are separate from citizenship status. Dual nationals in the US face citizenship-based taxation regardless of where they reside. This is unique to the US but affects millions of globally mobile individuals.

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How Global Investments Can Help

Building an optimal passport portfolio — whether as a single additional citizenship or as a carefully sequenced strategy across multiple jurisdictions — requires navigating the dual nationality rules of every country in your citizenship history and intended portfolio. Our advisers assist clients with:

• Mapping the dual nationality implications of each potential citizenship acquisition
• Assessing the risks and practical consequences in countries of origin that restrict dual nationality
• Coordinating with specialist immigration lawyers in all relevant jurisdictions
• Integrating passport strategy with tax residency planning and estate structuring

Contact us for a confidential consultation to discuss your specific circumstances and objectives.

This guide reflects the position as of 2026 and is for general information only. Nationality law changes frequently and varies by individual circumstances. Always take qualified legal advice before making any decision about citizenship or renunciation. Global Investments does not provide legal or immigration advice.