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Dual citizenship: Special regulations apply depending on the country of origin.
Expert article on citizenship law
What applies to the USA, Canada, EU states, Türkiye and other countries since the 2024 StAG reform
Anyone in Germany who wants to apply for naturalization or, as a German citizen, acquire another citizenship, primarily asks themselves one question: Can I keep both? Since the reform of the Nationality Act on June 27, 2024, the German answer is generally yes. However, the legal situation of the other country may stipulate otherwise. This overview shows which special regulations apply to the most important countries of origin.
Dual citizenship since the 2024 reform: the new basic rule in Germany
With the entry into force of the reformed Nationality Act (StAG) on June 27, 2024, the central rule of German citizenship law was reversed. Until then, anyone wishing to become a German citizen had to relinquish their previous citizenship. Exceptions were only provided for EU citizens and Swiss nationals. Since the reform, the opposite is true: dual citizenship is now the legal norm.
Specifically, this means two things. First: Anyone who becomes a German citizen may retain their original citizenship without restriction – regardless of their country of origin. Second: Germans who acquire another citizenship abroad no longer automatically lose their German citizenship and no longer require a retention permit.
With this, Germany has aligned itself with the majority of Western European states. However, what is permitted under German law is not mirrored in the law of other states. Some countries retain obligations to surrender assets or automatic consequences of loss – sometimes with significant repercussions for those affected.
Before applying for naturalization or accepting a foreign nationality, have both legal systems reviewed by a lawyer to avoid unintended consequences of losing your citizenship.
Dual citizenship Germany-USA: what has changed for Americans and Germans
The relationship between Germany and the United States of America is one of the most common dual citizenship situations worldwide. Both countries now allow dual citizenship without restrictions – the legal hurdle is therefore significantly lower than before 2024.
Americans who become naturalized citizens of Germany do not have to relinquish their US passports. Conversely, Germans who become US citizens through naturalization do not lose their German citizenship. The previously required retention permit has been abolished.
Three issues nevertheless arise regularly in practice. First, tax liability in both countries: The USA taxes its citizens worldwide according to the personal taxation principle. Even those who live and work exclusively in Germany must, as US citizens, file an annual tax return with the IRS and, if applicable, claim foreign tax allowances. In addition, there is the FBAR reporting requirement for accounts exceeding US$10,000.
Secondly, military service in the USA: Male US citizens between the ages of 18 and 25 must register for the Selective Service – even if they live in Germany. Thirdly, travel and passport issues: Dual citizens may enter and leave the EU with their German passport, but must use their US passport to enter the USA.
Dual nationals with US ties should have the tax implications clarified by a lawyer or tax advisor as early as possible before submitting their naturalization application.
Dual citizenship with Canadian and EU citizens: uncomplicated situations
Canada allows dual citizenship without restrictions. Canadians who become naturalized citizens in Germany automatically retain their Canadian passport – and since the 2024 reform, the reverse situation no longer results in the loss of German citizenship. This makes the Germany-Canada situation one of the simplest in the world. Australia, New Zealand, Argentina, Brazil, Mexico, and Israel have similarly generous regulations.
Even for EU citizens, dual citizenship with Germany was possible long before the 2024 reform. EU member states and Switzerland were already exempt from the obligation to relinquish their German citizenship under the old law. Since the reform, this exemption applies universally, but for EU citizens, practically little has changed.
Within the EU, however, some countries have their own restrictions. The Netherlands generally requires the renunciation of Dutch citizenship for naturalization abroad. Exceptions include spouses of Dutch citizens, children born in Germany, or cases of particular hardship. Spain only allows dual citizenship with Latin American countries and a handful of other countries, but not with Germany.
Anyone coming from an EU country with its own restrictions should have the legal situation in their home country specifically checked before applying for naturalization in Germany.
Special case Türkiye: Dual citizenship Germany-Türkiye between reform and reality
With over three million people of Turkish origin living in Germany, Turkey is one of the most important countries with dual citizenship. Legally, Turkey has allowed its citizens to hold multiple citizenships since 1981 – albeit with a number of formal requirements.
Before the 2024 reform of the German Nationality Act (StAG), Turkish citizens were regularly required to renounce their Turkish citizenship upon naturalization in Germany. With the reform, this obstacle has been removed: Since June 2024, Turkish citizens have been permitted to acquire German citizenship and retain their Turkish passport.
An important special case concerns the Mavi Kart (Blue Card) – a status for former Turkish citizens who lost their Turkish citizenship through prior naturalization in Germany. Holders of the Mavi Kart have almost the same rights in Turkey as Turkish citizens, with the exception of the right to vote and to hold civil service positions. Those who hold a Mavi Kart can, under certain conditions, regain Turkish citizenship.
Military service is another practical issue. Male Turkish citizens between the ages of 20 and 41 are generally subject to Turkish military service. Those living abroad can buy their way out of military service by paying a fee.
Anyone of Turkish origin planning to become a citizen in Germany should clarify the consequences of military service, the Mavi-Kart options and inheritance law in the family context beforehand.
Countries with restricted or prohibited multiple citizenship: Iran, Russia, China, Austria, Japan, India
Several countries of significant importance to German migration are taking their own approaches to the issue of dual citizenship. What has been permitted under German law since 2024 can lead to the automatic loss of the original citizenship under the law of the country of origin.
Iran and Russia: de facto dual citizenship with complications
Iran practically does not recognize the renunciation of Iranian citizenship. Anyone who becomes a German citizen after being naturalized remains Iranian from an Iranian perspective – even if they formally renounce their Iranian citizenship. This has consequences, especially for travel to Iran: Iranian authorities generally treat dual nationals as Iranians, with consequences such as mandatory military service, limited consular protection from Germany, and special passport requirements.
Russia generally permits dual citizenship. However, since 2014, Russian citizens have been required to report the acquisition of a foreign citizenship to the Russian authorities; otherwise, they face fines or prosecution. Since the war in Ukraine, significant practical complications have arisen, particularly regarding travel, banking, and property matters.
China: automatic loss of citizenship upon acquisition of a foreign nationality
The People's Republic of China generally does not permit dual citizenship. Anyone who acquires Chinese citizenship and then another nationality automatically loses their Chinese citizenship according to Article 9 of the Citizenship Law of the PRC. Reinstatement is possible, but subject to strict conditions. Hong Kong and Taiwan have different, more favorable regulations for dual citizens.
Austria and Japan: Dual citizenship deliberately excluded
Austria still prohibits dual citizenship. Anyone who becomes a German citizen automatically loses their Austrian citizenship – unless the Austrian Federal Ministry of the Interior has previously granted a retention permit. This permit is only granted in very limited exceptional cases, such as when there is a special public interest or in cases of economic hardship.
Japan does not recognize dual citizenship. Japanese citizens who acquire another nationality must choose between them within two years. Otherwise, they risk automatic loss of their Japanese citizenship under Article 14 of the Japanese Citizenship Law.
India: no dual national status, but OCI card as an alternative
India prohibits dual citizenship. Anyone who acquires another nationality as an Indian citizen automatically loses their Indian citizenship. However, since 2005, India has offered the Overseas Citizen of India (OCI) status: Former Indian citizens can obtain a lifelong entry and residence permit, which, while not citizenship in the strict sense, grants practically comparable rights – with the exception of the right to vote and certain public service professions.
In all these situations, a careful preliminary review of both legal systems is crucial to avoid any unintended loss.
When is legal advice worthwhile in cases of dual citizenship?
Legal advice from a specialist lawyer is always advisable when the applicant's home country's legal system contains special provisions – which is the case for most of the countries described here. Especially in complex situations, proactive legal clarification can determine the success or failure of the entire endeavor. This includes second-generation dual citizens, claims for naturalization, naturalization as compensation, and issues of loss and retention of citizenship in already concluded proceedings.
A specialized immigration lawyer examines both legal systems, identifies potential pitfalls, coordinates document procurement, and, if necessary, represents the client before German or foreign authorities.
Conclusion: Dual citizenship with Germany
Since the reform of the Nationality Act on June 27, 2024, dual citizenship is the default legal arrangement in Germany. Foreign nationals who are naturalized may retain their original passports. Germans who are naturalized abroad no longer automatically lose their German citizenship.
The crucial point remains: What is permitted under German law is often regulated differently under the law of the other country. A proactive review of both legal systems protects against the unintentional loss of one's original citizenship or unnecessary complications with future travel, inheritances, or family matters.
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FAQs – Frequently Asked Questions about Dual Citizenship
Yes. With the entry into force of the reform of the Nationality Act on June 27, 2024, dual citizenship is the legal norm. Anyone who is naturalized in Germany may retain their previous citizenship. Germans who are naturalized abroad no longer automatically lose their German citizenship and no longer require a retention permit.
The two terms are often used synonymously in everyday language. "Multiple citizenship" is the legal umbrella term for any situation in which a person possesses two or more nationalities. "Dual citizenship" is the established, everyday term that specifically describes two nationalities.
Countries that allow dual citizenship without practical restrictions include the USA, Canada, Australia, New Zealand, Great Britain, France, Italy, Poland, Brazil, Argentina, Mexico, Israel, and Turkey. In all these cases, German naturalization does not automatically lead to the loss of the original citizenship.
Dual citizenship is strictly prohibited in Austria, Japan, India, the People's Republic of China, and Spain with respect to Germany. In these cases, German naturalization regularly leads to the automatic loss of the original citizenship under the respective national laws – regardless of what German law permits.
No. The previously required retention permit under Section 25 Paragraph 2 of the German Nationality Act (StAG) was abolished with the 2024 reform. Germans who acquire a foreign nationality abroad no longer automatically lose their German citizenship.
Tax liability is generally determined by residence, not nationality. An important exception is the USA: it taxes its citizens worldwide. Therefore, dual US-German citizens must also file a US tax return in Germany and, if applicable, comply with the FBAR reporting requirements for foreign accounts.
Several countries require their citizens to perform military service, regardless of their place of residence. Of particular practical relevance are the USA (Selective Service Registration for men between 18 and 25), Turkey (conscription for men between 20 and 41 with an option to buy their way out), and Iran. The current legal situation should be checked before any trip to one's home country.
Providing false or incomplete information during the naturalization process is a criminal offense and can lead to the rejection of the application, the subsequent revocation of naturalization already granted, and criminal prosecution. Concealing existing citizenship or an ongoing investigation also falls under this category.
Yes, in certain circumstances, loss of citizenship is possible. The most important grounds for loss are enlisting in the military service of another country without authorization, participating in combat operations for a terrorist organization abroad (§ 28 StAG), and an explicit renunciation of citizenship. Revocation of naturalization is also possible if it was obtained through fraudulent misrepresentation or false information.
Legal advice is particularly advisable if the country of origin has its own restrictions, if a loss of citizenship already incurred needs to be reviewed or reversed, in complex family situations spanning several generations, and when applying for naturalization based on restitution or OCI status. A specialized immigration lawyer will examine both legal systems and guide you through the entire process.
