Dual residency allows individuals to legally live, work, and maintain residency status in two different countries. With globalization and remote work opportunities on the rise, an increasing number of people are interested in the benefits, requirements, and considerations of being a resident in multiple countries.
Dual Residency: Overview
Dual residency refers to the state of legally residing in two different countries and complying with each country’s residency requirements. Unlike dual citizenship where individuals hold legal citizenship and passports from two nations, dual residents typically only hold citizenship and a passport from one country.
Dual residency provides benefits such as greater mobility, flexibility, diversification of assets, and potential tax advantages. However, obtaining and maintaining dual residency status requires meeting legal residency requirements in each country. It also requires compliance with immigration and tax laws.
Definition of Dual Residency
Dual residency means having the legal rights to live and work in two countries by meeting each country’s residency requirements. Residency generally requires living in a country for a specified minimum period each year and demonstrating ties to that country.
To qualify as a dual resident, you must comply with the residency laws of each country. This typically means spending a sufficient amount of time in each country every year and providing substantial connections like a home, bank account, driver’s license, etc.
Importance of Dual Residency
In today’s increasingly globalized world, dual residency provides greater flexibility and options. With economies and immigration laws in flux, having residency in two countries provides a legal safety net and mobility.
Dual residency allows you to move between two places you call home. It provides legal rights to work remotely or live in two desirable places. It also offers the ability to move assets and shift tax burdens between countries.
For many, the insurance of having residency in a backup country in case of political turmoil, economic instability, or pandemics makes dual residency an appealing option.
Benefits of Dual Residency
Dual residency offers many potential advantages:
Global Mobility and Flexibility
The most immediate benefit of dual residency is the ability to easily move between two countries. Dual residents can live part time in two different places and commute internationally for work or personal reasons.
Dual residency provides flexibility to live or work globally. You can choose to spend summers in one country and winters in another. Or you can alternate years between countries. This mobility helps accommodate global business opportunities and a desire to experience different cultures.
Access to Multiple Social Systems
As a dual resident, you gain access to national benefits like healthcare, education, and pensions in each country. This allows you to take advantage of different social systems.
For example, you may be able to access free healthcare in one country and preferred university systems in the other. Some countries offer generous government pensions, which dual residency enables collecting from two nations.
Diversification of Assets
Having a residency in two countries makes it easier to own property, bank accounts, investments, and businesses in each place. This allows for greater asset diversification, especially across different currencies.
Spreading assets cross-border provides insulation from single country risks like bank failures, currency devaluation, and asset seizures. Dual residency can facilitate moving assets to the safest or most advantageous jurisdiction.
Tax Benefits
Each country has its complex tax laws regarding residents. But structured properly, dual residency can provide tax advantages in areas like income, property, inheritance, and capital gains.
- For example, you may be able to take advantage of lower income and capital gains rates in one country versus the other.
- Some countries do not tax worldwide income or only tax income earned while physically present there.
- Dual residency may also enable transferring assets and inheritances tax-free across borders.
Proper tax planning is essential to ensure compliance and realize the potential tax benefits of dual residency.
How to Obtain Dual Residency
Obtaining dual residency requires meeting the residency requirements of two countries. While requirements vary significantly, there are common criteria:
Legal Requirements for Obtaining Dual Residency
- Permanent residency – Some countries provide permanent residency options that count towards dual residency status.
- Continuous residency – Most countries require maintaining residency for a specified period of time each year.
- Physical presence – You must prove being physically present in the country for a minimum number of days annually.
- Intent to reside – Demonstrating you intend to reside in the country permanently through economic, social, and family ties.
Permanent Residency (Green Card)
Some countries offer permanent resident status or green cards for foreigners. Obtaining permanent residency in a country like the United States is one path towards dual residency.
A green card holder must spend a certain number of months in the US each year to maintain residency status. This allows dual residency by meeting the requirements of your home country and the US.
Continuous Residency
Most countries require a period of continuous residency before qualifying for permanent residency or citizenship. For example, Canada and Australia generally require permanent residents to be present 3 years before applying for citizenship.
Maintaining continuous residency while also meeting another country’s residency laws enables achieving dual resident status. Planning is essential to coordinate complying with both sets of residency requirements.
Physical Presence
Nearly all residency laws require a minimum period of physical presence in the country each year. For example:
- UK – At least 183 days per year
- France – At least 183 days per year
- Canada – At least 183 days per year
- UAE – At least 180 days per year
Careful planning is needed to coordinate the required days in each country to achieve dual residency. Some countries provide exceptions for short absences or overseas work.
Diversity Visa (DV) Lottery
Some countries including the United States offer diversity immigrant visas through annual lottery programs. Obtaining one of the limited diversity visas provides a path to permanent residency and eventually dual residency.
However, the odds of being selected are low at just 1-2% each year. And applications involve a lengthy process with no guarantee of success.
Dual Citizenship Considerations
Residency differs from dual citizenship, so it’s important to understand the legal implications. Dual citizenship provides further benefits but also has restrictions.
Restrictions and Requirements for Dual Citizenship
- Not all countries allow dual citizens – For example, Japan requires relinquishing existing citizenship when naturalizing as a Japanese citizen.
- Taxes – Countries may tax the worldwide income of citizens regardless of where they reside.
- Military service – Some countries require military service for all male citizens.
- Travel restrictions – A handful of countries restrict or forbid travel by dual citizens.
Examples of Countries that Allow Dual Citizenship
- United States
- Canada
- United Kingdom
- France
- Spain
- Switzerland
- Australia
- New Zealand
Most countries now accept dual citizenship, but some still place restrictions, so verify the laws.
Maintaining Lawful Residency Status
Importantly, obtaining dual residency or citizenship in itself does not override typical visa requirements for visitor travel between countries. Citizens or residents still need to carry passports and any required visas when crossing borders.
Dual residents must take care to maintain lawful immigration status in both countries. Obtaining long-term visas or permanent residency protects against risk of unlawful presence or illegal stay.
European Citizenship by Investment
Several European countries offer residence and citizenship by investment programs that provide a streamlined path to dual residency.
Overview of European Citizenship by Investment
Most programs require an investment in the country of several hundred thousand euros in exchange for permanent residency or citizenship. Investments are typically through:
- Government bonds
- Real estate purchases
- Capital contributions
Benefits beyond residency rights include visa-free travel within the EU. Programs exist in Bulgaria, Malta, Portugal, and other countries.
Here are some of the most popular citizenship-by-investment programs in Europe for dual residency:
Hungary Residency Program
- Minimum 300,000 EUR real estate investment
- Residency in 3-6 months
- Fast track dual citizenship option
Greece Residency Program
- 250,000 EUR minimum real estate purchase
- Family members included
- Schengen visa-free travel
Spain Residence Program
- 500,000 EUR minimum property purchase
- Investors eligible after 5 years for citizenship
- Visa-free EU travel
These programs provide a straightforward path to dual residency compared to traditional immigration routes. They remain very popular among global citizens seeking expanded rights and mobility.
Conclusion
Dual residency provides significant lifestyle benefits and advantages ranging from greater global mobility to potential tax savings. However, obtaining dual residency requires proactively meeting each country’s residency requirements and immigration regulations.
While residency eventually enables dual citizenship in some countries, they are distinct statuses with different legal implications. Those pursuing dual residency need professional cross-border tax and legal expertise to navigate often complex requirements.
With smart planning, dual residency can facilitate living an increasingly borderless, globalized life. Given the uncertainty of today’s world, having legal footholds in multiple countries is an attractive proposition for those with the means and motivation.
The keys are understanding the laws, hiring experts, and closely coordinating to meet obligations in each country. With preparation and care, nearly anyone can successfully achieve the benefits of legally residing in two or more countries.
