What You Need to Know About German Dual Nationality
Our clients often ask what acquiring German citizenship actually means. The most common questions that arise are:
- Can I keep my current citizenship and still become German?
- Will there be tax implications on assuming German citizenship?
- Would any of my children have to serve in the German military?
- Can my spouse also naturalise? What if we all wanted to move to Germany/the EU?
Here’s a general guide to help explain the implications of German dual nationality. First, let’s address the questions above:
Can I Keep My Current Citizenship and Still Become A German Citizen?
Germany has traditionally taken a restrictive approach to dual nationality. Although changes were introduced in June 2024, dual citizenship is still typically accepted only under certain circumstances, particularly for those living outside of Germany.
There are, however, exceptions. These include those who qualify for restoration of German citizenship lost due to Nazi persecution under Article 116 II GG; those eligible for compensatory naturalisation where a German residence had been given up due to persecution under Section 15 StAG; and those eligible for declaratory naturalisation under Section 5 StAG.
In contrast to applying for regular German citizenship (that is not related to Nazi persecution), which could require you to surrender your current citizenship, restoring German citizenship under Article 116 II GG, Section 15 StAG or Section 5 StAG of the German Citizenship Act does NOT require any such surrender. These exceptions are deemed compensation for the injustice caused by the Nazis or, in the case of Section 5 StAG, for discrimination against women and their ability to pass on German citizenship. In these cases, you are fully permitted to keep any citizenship/s held at the time of receiving your German citizenship.
We have evaluated German dual nationality based on those who hold existing UK and US nationality. We can confirm that, at the time of writing, neither country objects to multiple nationalities – as outlined here for the UK and here for the USA. We do, however, work with clients across the globe, and requirements may differ depending on your current nationality. South African citizens, for example, must apply for a permit of retention prior to accepting a German naturalisation certificate. This is very much country-dependent and, if in doubt, you should verify this with a specialist in the laws of your current nationality.
Please also note that once German citizenship is restored, you risk losing it again if you apply for yet another country’s citizenship. Should this become relevant, a petition to retain your German citizenship should have been granted prior to obtaining any additional citizenship. The application can be filed via your local German embassy or consulate.
Are There Tax Implications on Obtaining German Citizenship?
German Citizenship Restoration cannot provide tax consultancy services. Therefore, the following is not in lieu of advice from a tax consultant.
Principally, in order to be liable for taxation in Germany, you would have to be a German resident for tax purposes, i.e. have your ordinary place of residence in Germany. Otherwise, you may be liable for “limited taxation”, which essentially means that you pay taxes on revenues incurred in Germany only.
Will Any of My Children Have to Serve in the German Military?
There is current no compulsory military service in Germany. Formerly, it was mandatory only for German residents and, therefore it is highly unlikely that non-residents would be called to service should mandatory military service be reintroduced.
It is important to note that once naturalised, German citizens can lose their citizenship if they volunteer to serve in the army of another nation. Should this become relevant, feel free to contact us prior to acting for advice on how to try to retain your German citizenship.
Can My Spouse Also Naturalise? What If We All Wanted to Move to Germany / the EU?
Whilst the process of citizenship restoration does not include spouses, in the case of relocation to Germany or any other EU country, it is much simpler for spouses to obtain a residence permit.
After a certain period of time in Germany, it is possible to naturalise on the grounds of being married to a German citizen. However, under these circumstances, one may have to surrender existing citizenships, in accordance with the regulations of acquiring German citizenship through the “non-persecution route” mentioned above.
Important to Know
Once citizenship is restored, if you wish to enter and exit Germany, you are required to use a German passport once it has been issued. When entering and exiting the country of your original citizenship, you will need to show that country’s passport at border control.
Also, when in the country of your original citizenship, the German embassy cannot provide assistance or protection, be it legal or otherwise. Likewise, the US embassy, UK embassy or the embassy of any other country of which you are a citizen cannot provide any assistance or protection whilst you are in Germany.
Should you require assistance in a third country, feel free to seek assistance from the embassy of your choice.
We hope that the above serves to ease your understanding of acquiring German citizenship and holding dual nationality. Should you have further questions, please don’t hesitate to contact us –