Dual citizens around the world

Henry Belot

If the Prime Minister is to be believed, Australians have wildly different expectations of our politicians than most Western democracies.

Malcolm Turnbull says voters wouldn’t support a referendum to change section 44 of the constitution, a once obscure passage that’s now claimed six political scalps including the former deputy prime minister Barnaby Joyce.

“I think it’s questionable whether Australians would welcome dual citizens sitting in their Parliament,” Mr Turnbull said.

But dual citizens are currently welcome — with a few caveats and clauses — in the parliaments of the United Kingdom, the United States, Canada, Germany and New Zealand, among others.

Our views — or at least the High Court’s clear interpretation of the constitution — appear to be more in line with the Egyptian and Israeli constitutions, which have hardline positions on dual nationals.

In the United Kingdom, there’s nothing to stop you running for parliament if you hold dual citizenship with Ireland, a Commonwealth nation or a handful of European Union countries with historic ties to the UK.

It’s not necessarily a problem in the United States either. Texas Senator Ted Cruz was born in Calgary and was a Canadian citizen until early last year.

He only renounced his dual citizenship when running for the 2016 GOP presidential nomination — a political problem but not necessarily a constitutional one.

The US constitution says the president and vice-president must be “natural born citizens”.

But the Harvard Law Review says Senator Cruz already complied with the constitution, as he was born to American citizens regardless of his birth place.

The movie-star-turned Californian governor, Arnold Schwarzenegger, famously retained his Austrian citizenship while serving in office.

Dual citizenship is not necessarily a political problem in Germany either.

The politician David McAllister, who was once considered a successor to Chancellor Angela Merkel, has British dual citizenship.

He’s the son of a Scottish soldier, but that didn’t stop him being Germany’s man in the European Parliament and chairing its foreign affairs committee.

Canada’s former Prime Minister John Turner in 1984 was a dual British citizen and the former head of the country’s Liberal Party Stephane Dion was French.

About a decade ago, at least 11 members of the Canadian Parliament were dual citizens.

New Zealand allows candidates with dual citizenship to be elected, although if they apply after they’re elected, then they have to resign from office.

When Labour politician Harry Duynhoven applied to renew his Dutch citizenship in 2003, there was a threat of a byelection until the Government tweaked the law to save him.

Lots of comparable countries are not as strict on dual citizenship as we are.

So it’s little wonder the international media have been transfixed with our constitutional circus, which will remain open for some time.

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Henry Belot is a political reporter in the ABC’s Parliament House bureau in Canberra. He has previously worked for The Canberra Times covering the federal public service. Henry has a masters degree from the University of Melbourne and has studied international security. He was a finalist in the 2016 Walkley Young Journalist of the Year Awards.

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ABC