Anybody up on UK and/or German citizenship laws?

Samnell · Jan 16, 2005

I'm working up a PC who happens to be the son of two foreign nationals living in the US. Mom is a German physicist and Dad is a British medievalist. They're legal permanent residents of the United States, but neither one has seen fit to become naturalized or gain full citizenship. They have a lot of ties to family in Europe and visit regularly. Both remain full citizens of their respective home countries.

By virtue of his birth in the United States, my PC is an American citizen. His parents are legally married per the laws of all three concerned countries. I know that US law currently allows multiple nationalities. Do UK and German law do the same?

I know if the PC has either, he can claim right of abode anywhere in the EU per those treaties. But I'm coming up dry trying to find out if either nation does recognize multiple citizenships. I don't especially need it for the PC, but it would be neat to know.

Jürgen Hubert · Jan 16, 2005

I dunno about the UK, but as for Germany he would theorethically automatically get German citizenship until the age of 23, whereupon he must choose which citizenship he must give up.

In practice, dual citizenship with "friendly countries" are relatively common (I know a few cases involving Austrian citizenship), and the authorities will often turn a blind eye. Besides, taking someone's German citizenship away because he refuses to give up another one might be unconstitutional (there is no court decision as yet), so no one has tried to press the issue so far.

So giving him German citizenship as well wouldn't be unreasonable.

tassander · Jan 16, 2005

Samnell said:
I'm working up a PC who happens to be the son of two foreign nationals living in the US. Mom is a German physicist and Dad is a British medievalist. They're legal permanent residents of the United States, but neither one has seen fit to become naturalized or gain full citizenship. They have a lot of ties to family in Europe and visit regularly. Both remain full citizens of their respective home countries.

By virtue of his birth in the United States, my PC is an American citizen. His parents are legally married per the laws of all three concerned countries. I know that US law currently allows multiple nationalities. Do UK and German law do the same?

I know if the PC has either, he can claim right of abode anywhere in the EU per those treaties. But I'm coming up dry trying to find out if either nation does recognize multiple citizenships. I don't especially need it for the PC, but it would be neat to know.

German law is basically ius sanguinis, i.e. if your parents are German you're German, as well, no matter where you're born. AFAIK the UK, just as the US, is closer to a ius solis, but I could well be wrong.
Multiple citizenships in Germany are possible, but they are the exception and difficult to get. Some years ago they were almost completely impossible, but this has changed a little. I believe that the UK is far more lenient in this regard. I'd say that it is most likely that your PC has UK citizenship in addition to his US citizenship.

Edit: wow, Jürgen was faster than me. Listen to him. He apparently knows what he's talking about.

Samnell · Jan 16, 2005

Jürgen Hubert said:
So giving him German citizenship as well wouldn't be unreasonable.

So technically he has to choose at twenty-three, but in practice he probably wouldn't be forced to do so unless Germany ended up in some kind of major geopolitical dispute with the UK or the US? Great! That could be fun to play with should it ever come up.

Any British people out there know enough to help me out with the UK citizenship?

Jupp · Jan 17, 2005

Apparently things have changed alot. Back in the early 80s I had to choose to either become Swiss or keep the German citizenship because the Germans wouldnt allow my parents and me to keep the German passport together with the new Swiss one. So now I have the red one with the white cross. Information about German dual-citizenship are a bit contradictionary nowadays. Sometimes you hear from people that are Swiss/German and some that had to give the German passport away to become Swiss. Probably a case-by-case thingie as some folks earlier said in this thread

MonsterMash · Jan 17, 2005

The UK does allow multiple citizenships - having one parent would allow British citizenship to be applied for, and as far as I can recall there is no age cutoff.

For real detail look at www.homeoffice.gov.uk

These days I wonder if multiple citizenships are diminishing in Europe as EU passport holders have the right to live and work in each others countries without too much difficulty (registering for tax, and usually a few other parts).

Bagpuss · Jan 17, 2005

My son (my wife is Spanish and I'm British) currently holds both a UK and Spanish passport. No one has ever mentioned that he might need to give one up.

Strangely Spain is one of I think two countries that requires the British authorities to notify them of the birth of a national in the UK.

Jonny Nexus · Jan 17, 2005

MonsterMash said:
The UK does allow multiple citizenships - having one parent would allow British citizenship to be applied for, and as far as I can recall there is no age cutoff.

For real detail look at www.homeoffice.gov.uk

It reminds me of a story I once heard (may or may not be true) about the how you could have dual US/UK citizenship back in the days when the US didn't allow it.

Apparently, you went through the US ceremony thing and handed over your UK passport, and then just trotted to the nearest British embassy and told them that you needed a new UK passport because the Americans had just confiscated yours during the citizenship process.

I'm pretty sure that there's never been an issue with UK citizens having dual citizenship. I once knew a bloke who had dual Kenyan/UK citizenship and apparently his proof of Kenyan citizenship was simply that the Kenyan authorities had written "this person is a Kenyan citizen" in the back of his *UK* passport.

MonsterMash said:
These days I wonder if multiple citizenships are diminishing in Europe as EU passport holders have the right to live and work in each others countries without too much difficulty (registering for tax, and usually a few other parts).

I think that's probably the case. You basically just need to get one EU passport and then the whole EU opens up to you. It's all pretty relaxed within Europe itself.

Technically, I can fly to Ireland on a buspass, but I have to confess that I've never had the bottle to try it for real.

Jürgen Hubert · Jan 17, 2005

It would be easiest if his parents made sure he had the German passport early one - if he applies for one later in life and the German authorities discover he has US citizenship as well, they might make a ruckus.

Did they live in Germany for some time after he was born, and did they make sure to get him a German passport - or did they visit a German embassy or consulate in the USA to fill out the paperwork? If yes, no problem. If no, thigs get problematic - he has the right to German citizenship because of his mother, but if he only decides to get it later in life he might get asked to give up his US one.

Piratecat · Jan 17, 2005

Holy cow, I can't believe that this thread actually has something to do with RPGs.

Anybody up on UK and/or German citizenship laws?

Samnell

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Jürgen Hubert

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tassander

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Samnell

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Jupp

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MonsterMash

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Bagpuss

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Jonny Nexus

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Jürgen Hubert

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Piratecat

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