Most people stop paying attention once a second passport is in hand, but a range of legal obligations can arise automatically—sometimes years later—and affect the holder, their children, and even their existing nationality.
Descent claims have deadlines
- Italy – Law 74/2025 – Only applicants who, by 23:59 Rome time on 27 March 2025, had filed with a consulate, received an appointment notice, or had a pending court claim retained access to the broad ancestry route. The Constitutional Court upheld the reform in March 2026. A reference to the Court of Justice of the EU was lodged in July 2026; the case will not be resolved for at least a year.
- Ireland – Citizenship through a grandparent is granted only after the applicant’s birth is entered on the Foreign Births Register. If a parent delays registration, the child can be permanently excluded. Current processing time is roughly one year.
Generation limits shift more often than most realise
- Italy – Claims now flow only through a parent or grandparent who held Italian nationality at the time of birth.
- Ireland – Extends to a grandparent; a great‑grandparent qualifies only if the intervening parent registers first.
- Slovakia & Bulgaria – Reach the third generation via facilitated naturalisation rather than automatic transmission.
- Slovakia (July 2026) – Removed the residence condition for descendants of Czechoslovak citizens born on Slovak territory.
- Canada (December 2025) – Dropped the first‑generation cap, but children born abroad beyond the first generation qualify only if the Canadian parent spent at least 1,095 days in Canada before the birth.
Naturalisation can cost the passport you already hold
- Austria – Requires surrender of existing citizenship before naturalisation is completed, unless advance permission is granted.
- India & Singapore – Do not recognise dual nationality at all.
- China (Article 9, Nationality Law) – Automatic loss of Chinese nationality the moment a Chinese national voluntarily acquires a foreign passport; no application or notice is required.
- Japan – Applies the same automatic loss rule.
- The loss may remain unnoticed until a passport renewal or a child’s inheritance claim brings it to light.
Military service follows the bloodline
- South Korea – Male dual nationals are liable for conscription. The window to renounce Korean citizenship closes on 31 March of the year the individual turns 18. Missing the deadline can force service or an exemption that may extend into the late thirties.
- Greece (Law 5265/2026, effective Jan 2026) – Tightened criteria for Greek men residing abroad, limiting the ability to defer service indefinitely.
- Turkey & Israel – Also conscript dual nationals under certain conditions.
Tax obligations that cross borders
- United States & Eritrea – The only major tax regimes that tie core income liability to citizenship rather than residence.
- U.S. persons abroad must file annual returns and are subject to FATCA reporting by foreign banks.
- Covered expatriates (net worth ≥ USD 2 million or average annual U.S. tax over the prior five years above the statutory threshold) are deemed to have sold all worldwide assets the day before renunciation. For 2026, the first USD 910,000 of gain is excluded; the remainder is taxed.
- Gifts and bequests from a covered expatriate to U.S. persons are taxed at 40 %, under regulations effective Jan 2025 with the first returns due July 2027.
- Canada – Imposes a departure tax when a person ceases to be a tax resident, treating most property as sold at fair market value at that moment, which can be triggered by emigration rather than an actual sale.
Citizenship can quietly expire without formal renunciation
- Denmark – A Dane born abroad who has never lived in Denmark automatically loses citizenship at age 22, unless loss would render the person stateless. Retention is possible only by:
- Living in Denmark for three consecutive months, or
- Spending a total of one year in Denmark before turning 22, or
- Filing a formal retention application between ages 20 and 22.
After the deadline, there is no mechanism to regain the citizenship.
Investor citizenships can be revoked
- European Union (April 2025) – The Court of Justice ruled in Commission v Malta that Union citizenship cannot be obtained solely through a commercial transaction. Malta repealed its citizenship‑by‑investment programme three months later.
- Cyprus – Has begun revoking citizenship from several hundred individuals naturalised under its closed scheme, including family members of the original investors.
- The Maltese ruling was later cited by Italy’s Constitutional Court when upholding its 2025 descent reform and by Italian state lawyers arguing that the former broad bloodline regime would have conflicted with EU law.
These obligations are already in force in many jurisdictions; they often become apparent only after a passport is issued. Prospective applicants should assess the full legal landscape—including deadlines, generational limits, dual‑nationality restrictions, military duties, tax exposure, and the risk of revocation—before committing to a second citizenship.
Source article: knightsbridge.ae
