Why does citizenship matter today more than ever? This is a question we are asked all the time at Passport Legacy, and the simple answer is this: citizenship defines a person’s mobility options, their career opportunities, their long-term security, potential for globalization and so much more. Citizenship is becoming increasingly important as the world gets smaller.
But what, exactly, is citizenship? According to the Oxford English Dictionary, citizenship is ‘The legal right to belong to a particular country’, but for me that is a fairly reductive way to look at it. To me, citizenship is where a person calls home, where they understand the local culture, where they have roots and a real connection to the country. However, being born somewhere isn’t the only way a person can achieve citizenship; this is indeed the most common way, but there are other routes such as birthright, naturalization, and of course, investment.
What is Birthright Citizenship
The first type of citizenship I want to talk about is birthright citizenship, as it is the most common. The concept of gaining citizenship due to the place you were born dates back thousands of years; historical records show this concept existed during the Ancient Roman era (roughly 450BC), however, it was more closely developed into the law we know now during the development of English common law in the 14th century, where it was stated that “anyone born within the King’s land was considered a ‘subject’”.
The Latin name for this concept is ‘Jus Soli’ – right of soil, and states that legal citizenship should be granted to anybody born within the territory of a country, regardless of the parent’s citizenship status. This contrasts with the other commonly known Latin concept ‘Jus Sanguinis’ – right of blood, which states that citizenship should be determined by the nationality of one’s parents.
So which countries practice Jus Soli today? Some of the most famous examples are the USA, Canada and Mexico. All of these countries (to varying degrees) grant automatic citizenship to anybody born on their soil, regardless of their parents’ nationality or citizenship. Canada, for example, not only offers citizenship to all born in the country, but also anybody born in their airspace and territorial waters.
There are also many countries in Latin America who practice Jus Soli, such as Argentina, Brazil, Jamaica, Peru, Chile and Colombia.
What is Citizenship by Descent
Citizenship by descent pertains to the aforementioned ‘Jus Sanguinis’ – right of blood. This concept states that a person’s citizenship should be determined by that of their parents or grandparents. Conceptually, Jus Sanguinis also shares ancient origins with Jus Soli, however, the formalization of this concept came much later, in the 18th century.
Many countries in Europe practice Jus Sanguinis, such as Germany, France, Spain, Italy and Switzerland. There are also countries in Asia such as Japan, China and India, as well as Nigeria and South Africa on the African content.
However, it is worth noting that many countries across the globe combine principles of both Jus Sanguinis and Jus Soli in hybrid systems that consider parental nationality rather than direct place of birth; it is rare to find a country that practices universal and unrestricted versions of either.
What is Citizenship by Naturalization
The next type of citizenship I want to cover is citizenship by naturalization, a process where an individual can become a citizen of a country where they were not born by living in that country for a certain amount of time, as well as meeting certain other criteria.
This route to citizenship varies vastly from country to country, requiring 5 years residency in places like Portugal and the USA, all the way up to 30 years in places like the UAE. So, what are the common requirements of Citizenship by Naturalization? Usually, it will be a combination of (if not all) of the following:
- Minimum Residency
- Language Test (requiring you to be fluent or close-to)
- Integration
- No Criminal Record
- Knowledge Test (requiring you to have knowledge of the country’s history and principles)
- Intention to Reside
- Oath of Allegiance
Each country has its own rules when it comes to naturalization, and naturalization can be paired with Residence by Investment programmes in order to gain citizenship.
Citizenship by Investment
Citizenship by investment is becoming an increasingly prominent and viable option for individuals looking to gain citizenship in a foreign country. Why? Because often it’s the clearest path to citizenship, as well as containing straightforward and transparent processes and clear parameters.
There are typically two types of Citizenship by investment: direct programmes like St Lucia, St Kitts & Nevis, Grenada and other Caribbean nations, as well as Vanuatu and Sao Tome & Principe. These countries grant citizenship outright to investors (assuming they meet the outlined criteria).
Then, there are programmes like the Portugal Golden Visa and Greece Golden Visa, which contain the aforementioned naturalization clauses and can lead to citizenship. These pathways are attractive for individuals who wish to live and work in a country but do not necessarily require citizenship right away.
There are many benefits of taking the citizenship by investment route, from higher levels of global mobility, to the ability to better tax plan & protect wealth, to family benefits such as education and healthcare. These benefits are a big reason as to why Citizenship by Investment is one of the most prominent avenues of achieving foreign citizenship today.
Summary
To summarize, the paths to obtaining a second citizenship cannot be viewed with a ‘one size fits all’ approach, and the different types of citizenship available mean there are many options to suit many different people from different backgrounds, ethnicities, and financial situations.
One thing remains certain; obtaining a second citizenship is becoming an increasingly powerful option for individuals, opening doors to more career opportunities, tax benefits, greater mobility, family safeguarding, wealth appreciation and access to better health & educational institutions. It’s no wonder more and more investors are looking at Citizenship by Investment as a way to safeguard their families’ futures.
If you’re interested in learning more about second citizenships, or would like to explore your options for citizenship by investment, feel free to reach out to me at felix.weinstok@passportlegacy.com
