Dateline: Istanbul, Turkey
A lot of people are looking for second passports these days. The big question for many of these people is not whether or not they need a second passport but where exactly they will obtain their second citizenship.
When I first started traveling outside the United States on my own about eleven years ago, my first inclination was that a European passport would meet my needs. I felt that I was going to feel more comfortable there.
I began by traveling to places like Norway, Ireland and the UK. Especially in places like Norway, I felt like people were smarter and more plugged in. I didn’t necessarily agree with the socialism, but for someone with a global perspective, the Norwegian ethos fit my identity.
Now, after traveling to many more places and having experienced a great deal more, I have come to better understand the true value of citizenship. As we discuss in the methodology used to produce our Nomad Passport Index, citizenship is about more than identity.
My original desire to “be European” has now fallen in line with my desire to become a European citizen: I have respect for the citizenship process but my personal desire has diminished.
However, I understand that my diminished desire does not mean that many of my readers feel the same way. In fact, many of the people who come to me for help initially tell me that they are specifically looking for citizenship in the European Union.
I respect that desire, but I always try to dig a little deeper and understand why it is they are interested in European Union citizenship.
Many times, I have found that these individuals don’t really know why they want EU citizenship except that they want a “good passport.” They have fallen into the trap of collecting shiny objects instead of compiling a portfolio of useful tools that fit their personal international strategy on a holistic level.
It is one thing to say that you want to be European, it is another thing entirely to actually take the steps to become a European citizen when it may not serve you in the future.
That is why this article will not only explain how you can become a European citizen but also focus on the tough questions that will help you determine whether or not European citizenship is something that you actually need.
Before we jump into the details, though, let’s clarify what “European” citizenship means.
For the purposes of this article, we will focus on European Union and EEA citizenship. While countries like Norway and Switzerland are not part of the European Union, they are still part of the European Economic Area (EEA) and are almost universally considered to be part of western Europe.
If you are interested in cheap residences and cheap naturalization for European countries outside of the EU and EEA, you can find some of our best suggestions here and here. Countries like Albania, Serbia, and Montenegro offer European residence and/or citizenship programs for a much more affordable price tag, but they are not part of the European Union.
It is important to note the difference.
Who Is Getting the Second Passport?
One of the most relevant questions to ask at the beginning of any dual citizenship process is “Who is getting the second passport?”
When people come to me, I like to do a lot of intake because I really want to understand who the person is and what their needs are. Obviously, I can’t do intake with you on a blog post, so we’ll have to settle by going over the main types of people who are looking for a second passport.
US citizens who wish to quickly renounce their citizenship or at least have the ability to renounce in the future. There are many reasons someone may want to renounce their US citizenship, including for taxes, privacy, investment opportunities (for example, many US cryptocurrency investors are barred from investing in ICOs), business limitations, and more. Pragmatically speaking, renunciation requires a second passport no matter what your reason may be.
Emerging World Citizens
Emerging world citizens losing opportunities because of “bad passports.” Chinese and Arab citizens are the largest investors in citizenship by investment programs. The Chinese alone make up more than 80% of the investment immigration marketplace. This is due in part to the Chinese cultural belief in the importance of having a Plan B, but it is also due to the fact that their passports are very restrictive. Imagine all the business that a Chinese businessperson is losing by not being able to go to Europe the same way that an American can. The wealthy in these and other countries can afford the cost of second citizenship in both time and money in exchange for the greatly increased travel benefits.
Business Owners and Investors
Business owners and investors looking for a “Plan B”. While US citizens have the most immediate need for a second passport and can often earn an immediate ROI, citizens of other countries can also benefit from having another citizenship in their back pocket… just in case. For example, I had an Australian couple come to me recently to work on their tax strategy, but they also explained that while they didn’t think anything bad was going to happen in Australia, they wanted to know the most affordable way to get a second passport just in case something were to happen.
Who Needs European Citizenship?
Of those three categories, who needs European citizenship?
For the first group – western (primarily US) citizens who are seeking second passports to have more options, including renunciation – my strategy has increasingly begun to exclude European Union citizenship.
Instead, what these individuals usually need is a portfolio of Tier B passports. Tier B passports are the wave of the future.
If you can compile a small passport portfolio of Tier B and even maybe one Tier C passport that gives you most of the travel that you want without having any of the tax or privacy or reporting or information sharing nonsense that the US has pioneered and the EU has started to follow, you might be better off without a European passport.
The same can be said for the third group. If you’re just looking for an insurance policy as an Australian, Canadian, etc., you might not need a European passport either. The ultimate compliment to a Tier A passport is not another Tier A passport but something that fills in the gaps and offers some privacy.
For example, I have a friend from the UK who already has all the travel options he could want with his UK passport. He doesn’t need another passport from a big, powerful country just to improve his travel options.
However, he is marrying an Armenian woman and he wants an Armenian passport to not only live in the country but also to have a second passport that is under the radar. No one has an issue with Armenia (except maybe Azerbaijan), they have visa-free options that he doesn’t get as a UK citizen, and if stuff really hits the fan in the UK, he’ll be a citizen of a country that doesn’t really care what he’s doing in the rest of the world.
The people who have the strongest need for European citizenship are those who have the “bad passports” that are restricting their travel. And I would still ask people in that group what a European citizenship does for them that a citizenship in St. Lucia (that grants visa-free access to Europe) does not.
That’s worth determining.
If you’re from the emerging world and you don’t trust your schools or your government and you want your kids to go to school in France, perhaps the EU passport helps facilitate that. But if you’re younger and merely looking for a way to get visa-free access to the EU to expedite your business efforts in the region, EU citizenship is not the only way to get what you need.
I have a lot of people who come to me who say that they need a European passport, but when I show them the extra bureaucracy, the extra paperwork, the extra waiting, the extra uncertainty and, in many cases, the extra cost involved in the process, they often reconsider.
I recently had a couple come to me who wanted to become European citizens. However, when they realized how much it would cost them compared to a cheaper residency in the Americas, they decided it was better to skip the European program and reinvest the difference of what they would have paid for a return of $100,000 over the next year.
For them, we determined that they had better options. If you’re in a similar situation, it’s worth discussing why you want European citizenship, how much it is going to cost you (in money and time) and what you could do with that same investment if you were to put it elsewhere.
How to Become a European Citizen
If you examine your personal situation and ultimately decide that European citizenship is the solution to your needs, there are a few different ways to get European citizenship.
These options mirror the four different paths to citizenship you’ll find anywhere in the world:
1. Citizenship by Descent – If you have a parent, grandparent, and in some cases a great grandparent who was a citizen of a European country and you meet certain conditions (which can often be nebulous or arbitrary) you can become a citizen of that country.
2. Naturalization – You obtain a residence permit in your European country of choice and then sit back and wait for the naturalization clock to run its course.
3. Citizenship by Investment – You make an investment in the country and, in return, the country grants you citizenship.
4. Citizenship by Exception – A government body (parliament, the prime minister, the president, etc.) has the power to grant you citizenship, often based on exceptional merits.
Let’s go through each option and take a look at where each one is available in Europe.
1. Citizenship by Descent
Citizenship by descent is the most common means of obtaining citizenship in Europe, or at least it is the first option that comes to mind when most people consider the process. While common in Europe, some of these programs can be very arbitrary and time-consuming.
Germany only allows citizenship by descent to be traced back one generation. In other words, if your parent was a German citizen at the time of your birth, you can claim German citizenship.
Germany is very selective about who is allowed to obtain German citizenship by descent and even more restrictive of who can keep their second citizenship. However, if an individual acquired another citizenship at birth, they can usually maintain dual citizenship once approved for German citizenship by descent.
Following Trump’s election, many US citizens with German parents decided to claim their German citizenship by descent.
While Greece has a very liberal policy of allowing its citizens living abroad to hold dual citizenship and transmit their Greek citizenship to their children indefinitely from one generation to the next, the one caveat is that you must prove that you are an ethnic Greek.
Technically, a child of a Greek citizen is automatically considered a Greek citizen at birth, but they must be registered. If this was not done, an ethnic Greek can apply for citizenship by naturalization if they can prove that at least one parent or grandparent was born a Greek citizen.
Similar to the Greek citizenship by descent program, there is technically no limit on how far back into your family tree you can go to find a Hungarian ancestor.
While most of the few new Hungarians obtaining citizenship through ancestry do so going back three generations, you could go back even further if you could establish a paper trail that connected each generation to the next… and all the way to you.
It is rare to see a citizenship by descent program be so generous in its timeline, but don’t get your hopes up. Hungary has not been so foreigner-friendly as of late and you can expect to run into a lot of roadblocks along the way.
You can read more about Hungarian citizenship by descent here.
I’m helping someone right now get Irish citizenship by descent and I would have to say that it is the least arbitrary program of them all. It is straightforward and relatively easy.
You are automatically considered an Irish citizen if you were born in Ireland to an Irish citizen or an Irish resident of at least 3-4 years at the time of your birth. You also qualify if you were born outside of Ireland to an Irish citizen born in Ireland.
You can also obtain Irish citizenship by registering with the Foreign Births Register if:
- You were born outside of Ireland to Irish citizens also born outside of Ireland, and your grandparents were Irish citizens born in Ireland; OR
- You were born outside of Ireland, your parents were born outside of Ireland but were registered on the Foreign Births Register before you were born, and your grandparents were born outside of Ireland to Irish citizens born in Ireland.
You can learn more about Irish citizenship by descent here.
Whereas Ireland’s program is simple and efficient, Italy’s citizenship by descent process can take forever.
I have one friend who has been waiting three and a half years for his Italian passport. Someone with a decent income could pay as much as $800,000 or more in taxes in that amount of time while they sit around and wait for the Italian government to approve their application.
That said, Italy does allow you to go back to at least your great grandparents, if not further in order to claim citizenship by descent. However, if your goal is to get a passport for financial purposes, you’ll often be better off just buying a passport in St. Lucia and getting your passport in a matter of four or five months.
You can learn more about Italian citizenship by descent here.
In Lithuania, you are typically allowed to go back three generations – i.e., great grandparents – it’s just a matter of proving the family connection via your own birth certificate and the birth certificates (and sometimes marriage certificates) of everyone in your family tree back to the ancestor with Lithuanian ties.
Each document must be notarized in the country or state (in the US) where the document was issued. For the most part, you have to rely on the archives in Vilnius by using a local attorney to help you. I have gone through the process and it is hard to prove.
Another important note is that the Lithuanian government has gone back and forth on whether or not to allow dual nationality and even whether they should allow ancestral citizenship cases at all. If you still want to give it a try, the process usually takes about a year and a half to complete.
You can learn more about Lithuanian citizenship by descent here.
Like Hungary, Poland has been feeling particularly anti-foreigner as of late. So, while they still offer a citizenship by descent program, they have recently added a Polish language requirement that has made the process even harder than it already was.
The basic condition for claiming Polish citizenship by descent is that you have Polish ancestors who left the country after Poland became an independent country in 1918. That means you’ll have to use ancestors who were born in the twentieth century.
Poland also requires that you maintain an unbroken chain of citizenship in order to qualify. If your great grandfather qualifies, but your grandfather gave up Polish citizenship to become a citizen of another country, you’re out of luck.
You can learn more about Polish citizenship by descent here.
The United Kingdom
The UK also offers a limited form of citizenship by descent. It is only available to children of British citizens and does not extend back any further.
If you were born outside the UK on or after January 1, 1983, to a UK citizen, you can claim your British citizenship. However, if you were born outside the UK to a UK citizen who gained their citizenship through the descent process, you no longer qualify for citizenship by descent.
All of these citizenship by descent programs come with their own timelines, citizenship requirements and potential roadblocks. Most, besides Poland, do not have a language requirement. They can take as little as nine months in Ireland to potentially years in other countries.
At the very least, I would encourage you to start the residency process somewhere else when you start one of these programs because it’s never guaranteed and they can deny you for nebulous reasons.
Many people like to pursue naturalization via programs that allow for what I call paper residence, where you simply go to the country and register as a resident, come back one day every year or two and, after five years, apply for citizenship.
Those programs are never guaranteed.
There have been some cases, like in Uruguay, where people thought they were getting paper residence but when they came back, the judge determined that they hadn’t really been in the country and denied them.
These types of programs do not exist in the European Union or the EEA. Do you think that France needs you to come in and drop $10k in a bank account just to come back in five years and become French? Absolutely not.
The naturalization route in Europe requires much more commitment than a simple paper residence. There are four main things European countries are looking for that will justify a residence permit that can lead to citizenship by naturalization:
You can get a job in Europe and qualify to become a resident. For instance, if you get a job offer in France and move to France and pay French taxes and learn French, you can become a French resident and, after a period of time, become a French citizen.
This option is available in basically every country in Europe.
Some countries offer shortened timelines for spouses of EU citizens. However, there are no EU countries that just instantly grant citizenship to spouses – it would be against EU principles. If EU countries chose to dole out citizenship to people they would have a ton of marriage fraud.
That said, if you marry an EU citizen, you can generally get a residence permit and work toward citizenship via naturalization just like everyone else. Some countries shorten the naturalization timeline for spouses, others do not, but all offer some type of route to citizenship via marriage.
If you start a business in any number of European countries, you can qualify for residence and work through the normal naturalization timeline to become a citizen. The key is that you have to run a real business.
I recently got rejected for an EU residency that I was trying out as an experiment. While they didn’t give an explanation for the denial, my suspicion is that my business wasn’t what they were looking for.
In some of the smaller countries, they are a bit more flexible on what constitutes a real business, but if you’re going to come in and just open a company like you would in Panama and then plan to come back and get a passport, it’s not really going to work.
Most countries have a business program. The inherent challenge with these programs comes back to the question of who you are and why you want to do business in Europe in the first place.
If you are Indian or Chinese, etc. and you want to move out of India because you’ve had enough of it and you want to move somewhere new, then sure, the idea of moving to Slovenia and running a business and paying some tax is normal.
However, personally, I already have a business and it is offshore and I benefit from very favorable tax setups because of that and I get to travel between countries that I like, none of which are really in western Europe, so I don’t want to go and pay 63% tax in Spain or France.
I’m not going to do that.
It’s possible, I suppose, to run a part of your business in one of these countries without growing it too big and increasing your tax burden. However, increasingly, the larger more desirable countries are looking at these smaller business plans and deciding that they don’t want tiny little businesses that make crumbs. They want real businesses.
If you want to go to the smaller countries like Slovenia and Slovakia, they may look more favorably at a business that has €50,000 a year in profit. You will pay some social security tax on a salary along with other taxes and they’ll call it good. That’s fine in places like Lithuania, but not every country is going to jump at the idea.
The challenge with these business options is that many of them require you to spend a considerable amount of time there.
In Estonia, for example, it takes eight years to become a citizen, you have to learn Estonian, and you have to spend at least six months of every year in Estonia. This time requirement means that if you have other things besides that business you’re going to pay tax on all of that income in Estonia… because you live there.
Lithuania has a program where you can hire three employees and contribute a nominal amount of capital to start up your company. But, again, you can’t just leave and never come back.
Latvia has a program that does not require you to stay there and you can keep the residence as long as you want. However, if you want to become a Latvian citizen, you have to live there nine months out of every year for ten years.
For people who want to spend unlimited time in the EU, having an EU residence permit will be enough to get you what you want. Then, instead of spending almost all of your time in Latvia in order to get a second citizenship there, you can use your business to get Latvian residence and then invest in a Tier B passport.
This will allow you to forego the demanding requirements for citizenship by naturalization in Europe while still giving you visa-free access to the EU and a second passport.
Other countries that offer residence in exchange for setting up a business include Belgium, Slovakia, Slovenia, and Hungary (although I believe they are a bit more arbitrary on rejecting people now because they just don’t like foreigners).
Several non-EU countries like Serbia and Montenegro have programs as well. Montenegro probably doesn’t care what you do, as long as they see stuff happening in your bank account – a little money in, a little money out. Belgium definitely cares and they are going to be very particular about approving you.
The challenge with the business option is that you need to live there to actually qualify for citizenship. For a true Nomad Capitalist, they’ll see this option as making you liable to pay a lot of money in tax and restricting your movement while you’re waiting for that passport – and no naturalization process in the EU is less than five years.
That’s a high level of commitment and a lot of time to be tied down to one place just to get citizenship.
A more straightforward process is to obtain residency by investment and then work through the naturalization timeline to obtain citizenship. This is different from citizenship by investment where you are automatically granted citizenship after making your investment.
In Europe, many investment immigration programs have come to be known as Golden Visas. While we’ll discuss some of the details of these programs below, you can find a detailed article on the topic here.
Portugal has a number of different options. The first is to invest capital by either transferring €1 million, capitalization on SME’s of €500,000, funding research activities with at least €350,000, or funding arts and culture with at least €250,000.
The second option is the most popular: invest in real estate. Investments start as low as €350,000, although this is for urban renewal projects that often involve investing in some kind of dilapidated old property out in the middle of nowhere. If you want to buy any property of your choice in a big city, it’s going to cost at least €500,000.
The third option is to create ten local jobs. There is no minimum investment amount for this option and they accept applications in any business area for any type of business.
Spain also has a Golden Visa program. It requires a €500,000 investment in real estate and it takes ten years after that to obtain citizenship. There’s really no benefit to this program and I don’t recommend it.
Greece has a Golden Visa program as well. In fact, for an investment of just €250,000 in property, it is the cheapest EU Golden Visa. However, getting the citizenship takes seven years and is a rather nebulous process (seeing as Greece only likes to give citizenship to ethnic Greeks).
The bigger problem with Greece is, who wants to buy property there? Certainly not the Greeks! Property taxes are high, it’s expensive, and who knows what that country is going to do.
Countries offer Golden Visas to investors for a reason.
With the business residence option, countries are inviting you to come in and start a business and integrate into society with the recognition that you are going to pay tax. That’s not a special regime, that’s how it works for everyone.
By contrast, with the Golden Visa in places like Greece, you’re buying property because no one else wants to. There’s a reason that the Netherlands doesn’t have a Golden Visa program. Their real estate market is fine. They don’t have problems getting people to buy their property. Greece does.
Latvia also has a program that allows for a real estate investment of €250,000, but they add to the cost by requiring you to either pay a state fee or deposit €280,000 in a bank term deposit that is locked up for five years at a time. (Again, you still have to live there before you become a citizen, otherwise, it only functions as a residence.)
The bottom line on naturalization in the EU is that getting in is the first step. People just want to get into the EU. Once you do get in, there’s really no fast track through naturalization.
The one fast track is in Bulgaria where you can become a citizen in five years by purchasing about €512,000 in government bonds that generate zero interest. If you want to double that investment to just over a million euros, they claim you can get it in just over one year.
However, there are questions as to whether people have even been naturalized through this program. Bulgaria is a part of the world, kind of like Greece, that has historically not wanted to naturalize people who weren’t really from that region. Keep that in mind if you do decide to pursue Bulgarian residence and citizenship.
There are fast track naturalization programs outside of the EU that are still in Europe, they are just in Eastern Europe and similar areas still outside the EU. If you want to learn more about those, you can contact me as part of creating a holistic passport portfolio.
3. Citizenship by Investment
There are two economic citizenship programs that you probably already know about by now that we have covered before in our list of the best citizenship by investment programs: Malta and Cyprus.
Cyprus offers the fastest naturalization process in the world at just 57 days. The citizenship process requires an investment of €2 million in real estate, government bonds, a bank deposit in a Cyprus bank, or an investment in a new company.
While pricier, you can invest the €2 million rather than make a donation like in most other programs. The catch is that you must own a €500,000+ home in Cyprus indefinitely and that home purchase will be subject to VAT.
Cyprus is not part of the European Schengen Area and the passport will not get you visa-free access to the United States.
The Maltese passport, on the other hand, is part of the borderless Schengen Area and is the only economic citizenship that offers visa-free access to all six English-speaking countries, including the United States.
There is quite a bit of conflicting information about how to get Maltese citizenship, but the main citizenship requirements include a €650,000 donation by the main applicant plus €25,000 for a spouse and each minor child, an investment of €150,00 in Maltese government bonds or stocks for a period of five years, and either a home purchase of at least €350,000 or a five-year lease contract for at least €16,000 per year.
You will also need to spend some time in Malta while you process your economic citizenship since it takes about 15 months for the Maltese government to issue your passport.
If you are willing to invest as much as €650,000 or more in your Nomad Strategy, another option would be to pursue a non-EU fast-track naturalization passport and combine it with a Caribbean citizenship by investment program like St. Lucia that will give you visa-free access to the EU.
You could invest less in both of those and get most of your money back (about 70%) for less money than you would donate to Malta. You may even have enough money left over to invest in bank deposits in Latvia or property in Greece, whatever fits your plan to get a European residence permit.
With a strategy like that, you could keep more of your money and get all of the privileges of visa-free access to the EU without any of the potential tax consequences in the future.
4. Citizenship by Exception
Numerous countries allow the president or parliament to naturalize anyone they want. This is not only true in the European Union, it’s true in many countries. In the EU, I am aware of two.
Some people call this a citizenship by investment program. It’s not. It’s highly arbitrary. You really have to prove yourself and invest ten million euros or donate several million.
“Proving yourself” involves currying favor with a local politician who can represent you and have the right people sign off on you.
Another issue for many folks is looking “Austrian enough.” From what my experience has been, if you’re Chinese, forget it.
Another downside here is that there’s no dual citizenship for Austrians. I don’t see any codification in law that would allow for a special exception. Some exceptional citizens are exempt from dual citizenship restrictions, but I don’t believe Austrians are.
I have heard the objection that the citizenship program isn’t codified in law, but I would have to disagree. It is in the law that anybody who meets the qualifications of the government ministers and is approved can be made a citizen.
What isn’t codified in the law is the exact process of how you become a citizen.
There is quite a bit of leeway when it comes to the process. If he wanted, I suppose the prime minister could make anyone he wants a citizen. What makes Austria a bit higher brow is that there is no list of people just paying the prime minister money in an envelope to do that.
I had someone who recently applied for citizenship by exception in Poland. He had been running a business in Poland for a number of years, he speaks some Polish, he has integrated somewhat into society, and he owns real estate.
The Polish government allows anyone to apply for citizenship just by sending in a letter and explaining why it is you want citizenship.
As an EU country (and as a currently xenophobic country), it is very difficult to get citizenship this way.
When I was dating someone from Poland, we went to a lawyer and talked about different options. If we were to get married, what would happen? Could we live in Poland part-time? Could I get a residence permit as a spouse and not have to live there?
But Poland is pretty strict.
They don’t want people taking advantage of them. That is why speaking Polish is going to be a must. Perhaps if you have a Polish grandmother and you get rejected through the embassy for your descent process, maybe the president would look at it, but the current president is not very favorable to these things, so I wouldn’t count on it.
Finding the Ideal Situation
Those are the four options available to anyone looking to become a European Union citizen: descent, naturalization, investment, or exception.
My view is that you have to be aware of the potential tax risks in the future before you jump into anything. There is always the chance that the EU might crack down on people who don’t live in their countries and demand that they report their taxes.
Already, if you use an EU passport to open bank accounts, that information will be reported back. For some people, like if you’re Chinese and you don’t want the Chinese to know what you have, that can be a benefit. For some of us, that could be a downside.
The EU and countries like the UK are increasingly cracking down on people who have unexplained wealth. That’s not going to be the case for most westerners, but you need to be aware that the EU might throw its weight around and impose some restrictions in the future on its citizens including reporting requirements, taxes, etc.
As I always say, you don’t want to jump from the fire into the frying pan. It’s worth considering what the ideal situation is for you before you decide that you need an EU passport.
Most westerners who come to me thinking that they need an EU passport, unless it’s a really simple issue – like you have a Dutch mother and want to get a Dutch passport that you can give up if it becomes a problem and it costs you nothing to get – should consider all of their options before insisting on European citizenship.
My recommendation is to seriously consider the merits of building an entire passport portfolio.
You don’t have to replace your US passport with an EU passport. In one guy’s case who I worked with recently, it would have cost him over a million dollars just waiting around to become a European Union citizen.
At some point, you have to ask yourself if it’s worth it and why you really want it.
Food for thought.