US & UK Dual Citizenship: Advice & Application Support From Immigration Lawyers

Page Contents

• What is Dual Citizenship?
• Who is Eligible?
• How Can You Apply for Dual Citizenship UK?
• Rights of Dual Citizens
• UK Dual Citizenship Application Fees and Processing Times
• How Can IAS Help?
• Frequently Asked Questions

Being American does not automatically make you eligible for British citizenship. If you need to apply through naturalisation, you must meet the applicable nationality and immigration requirements.

For the standard naturalisation route, you will generally need to:

• Be at least 18 years old.
• Have lived in the UK for at least five years before applying.
• Have held indefinite leave to remain (ILR), settled status or indefinite leave to enter for at least 12 months, unless the rules for your application route provide otherwise.
• Meet the applicable residence and absence requirements, including the physical-presence requirement on the relevant date.
• Meet the good-character requirement.
• Meet the English-language requirement or qualify for an exemption.
• Pass the Life in the UK Test, unless exempt.
• Meet the applicable intention-to-reside requirement.

The standard route generally permits no more than 450 days outside the UK during the five-year qualifying period and 90 days during the final 12 months, although the Home Office may consider permitted exceptions and discretion in appropriate cases.

If you are married to or in a civil partnership with a British citizen, a different route generally requires three years of residence. You do not normally have to wait 12 months after obtaining the relevant settled status, but you must meet the other requirements for that route.

US nationals generally do not need to prove their English-language knowledge by taking an approved test solely for naturalisation, because the United States is a recognised majority English-speaking country. Other requirements, including the Life in the UK Test, still apply unless you qualify for an exemption.

These are general requirements, and the correct route depends on your immigration and personal circumstances.

For a full explanation of qualifying residence, absences, exemptions and supporting documents, see the IAS guide to British citizenship requirements.

There are two initial steps: establish whether you already qualify as a British citizen and, if you do not, identify the appropriate route to acquiring citizenship.

1. Check whether you are already a British citizen

Some Americans may already hold British citizenship through birth or descent because of their own birth circumstances or a parent’s nationality.

British citizenship rules depend on factors such as when and where you were born, your parent’s citizenship and, in some circumstances, your parent’s immigration status.

If you are already British, you may be able to apply for a British passport rather than submit a naturalisation application.

Read the official guidance on British citizenship through a parent to check your circumstances.

2. Apply for British citizenship through the appropriate route

If you are not already British, you may qualify through naturalisation or an applicable registration route.

For most American adults who have moved to the UK and established the required immigration status and residence, naturalisation is the main route.

The requirements depend on your circumstances, including whether you are married to or in a civil partnership with a British citizen. Marriage alone does not automatically grant British citizenship.

You can review IAS’s British citizenship requirements for US citizens for more detailed eligibility information.

3. Complete the application and obtain your citizenship

If you qualify for naturalisation or registration, you must complete the appropriate application, provide the required supporting evidence and pay the relevant fee.

Applicants who successfully naturalise as British citizens generally need to attend a citizenship ceremony before they receive their citizenship certificate. They can then apply for a British passport.

The application process depends on the route you use, so check the relevant GOV.UK citizenship application guidance before applying.

What Are the Benefits of US–UK Dual Citizenship?

Holding both US and British citizenship can provide important advantages if you have family, work, property or other long-term ties to both countries.

The right to live and work in both countries

British citizenship gives you the right to live in the UK without needing immigration permission. Your US citizenship gives you the corresponding right to live in the United States. You can therefore move between the two countries for work, family or other personal reasons without needing a visa to establish your right to live there as a foreign national.

You must still comply with the laws and requirements that apply to your activities in each country.

Access to education and public services

Dual citizenship can make it easier to plan long-term residence, education and family arrangements in both countries. However, British or American citizenship does not automatically entitle you to every public benefit, healthcare service or education subsidy. Eligibility can depend on residence, contribution history, the type of service and other legal requirements.

For example, entitlement to free NHS hospital treatment in England generally depends on ordinary residence or an applicable exemption, rather than British citizenship alone. Rules and charging arrangements can differ across the UK.

Greater flexibility for international travel

Holding both nationalities may simplify international travel because you can use the appropriate passport to establish your citizenship and travel rights. However, visa requirements still depend on the destination country, the purpose of your visit and the passport you use. Some countries also impose specific rules on their own citizens who hold another nationality.

You should check entry and exit requirements before travelling.

Disadvantages and Tax Obligations of US-UK Dual Nationality

Although dual citizenship can offer greater flexibility, it is important to understand the obligations and limitations that come with holding two nationalities.

Tax reporting obligations

US citizens generally remain subject to US tax rules on worldwide income, even when they live outside the United States. Depending on your circumstances, you may need to file US tax returns and report certain overseas financial accounts. Foreign tax credits, the foreign earned income exclusion and other provisions may reduce your US tax liability. They do not automatically remove every filing or reporting obligation.

Your UK tax obligations depend separately on the applicable UK tax rules and your circumstances.

Legal obligations in both countries

As a dual citizen, you must comply with the laws that apply to you in each country. Particular responsibilities can vary depending on where you live, work, hold assets or exercise your citizenship rights. You should understand the rules that apply to your circumstances, especially if you intend to relocate permanently or maintain significant financial interests in both countries.

Limits on diplomatic assistance

A British–American dual citizen should not assume that both governments will always be able to provide diplomatic assistance in every situation. The UK government would not normally intervene on behalf of a British dual national in dealings with the authorities of the country of their other nationality. The availability of assistance depends on the circumstances.

You will need to pay fees when applying for British citizenship. The nationalisation fee is £1,709 for an adult and £1,000 for a child.

The cost of a citizenship ceremony is £130.

If you need to apply for a certificate of entitlement, the cost will be £589.

Once you have British citizenship, you can apply for a British passport. For applications made online from outside the UK, an adult standard passport costs £102 for a standard passport and £116 for a 54-page frequent traveller passport.

Processing times vary but you can expect to wait around three to six months for a decision on your application.

Which Passport Should US–UK Dual Citizens Use?

If you hold both US and British citizenship, you should understand the passport rules that apply when travelling to each country.

Travelling to the United States

US law requires US citizens, including dual nationals, to enter and depart the United States using a valid US passport. Your British passport does not replace this requirement.

Travelling to the United Kingdom

British dual citizens generally need to travel to the UK with one of the following:

• A valid British passport.
• Another valid passport containing a certificate of entitlement to the right of abode in the UK.
• A valid Irish passport, where applicable.

There are limited exceptions for certain travellers, including some people who became British citizens after settling in the UK under the EU Settlement Scheme. British and Irish dual citizens cannot obtain a UK Electronic Travel Authorisation (ETA) as a substitute for proving their citizenship. A US passport alone should therefore not be assumed sufficient for boarding a flight to the UK.

Travelling to other countries

The appropriate passport depends on the destination country’s laws. Some countries have additional requirements for their own citizens who also hold another nationality. Check the destination country’s official travel guidance before departure, including any rules on entering or leaving using a particular passport.

Can Americans Have Dual Citizenship in Scotland, England or Wales?

Yes. Americans can hold US and British citizenship while living in Scotland, England, Wales or Northern Ireland, subject to the relevant British nationality rules.

There is no separate Scottish, English or Welsh citizenship that you need to apply for. British citizenship applies throughout the United Kingdom.

If you intend to apply for British citizenship, your eligibility depends on the applicable nationality and immigration rules, not on whether you live in Scotland, England or Wales.

Which Countries Allow Dual Citizenship With the UK?

The UK generally permits its citizens to hold more than one nationality. However, the laws of the other country determine whether you can retain that nationality when acquiring British citizenship.

Some countries permit multiple nationalities, while others restrict dual citizenship or require people to take specific steps when acquiring another nationality. The rules can change, so a general country list should not replace official advice.

If you hold or intend to acquire another nationality alongside US and British citizenship, check directly with the relevant country’s embassy or consulate to establish whether multiple citizenships are permitted and whether any registration or renunciation requirements apply.

Do US–UK Dual Citizens Have to Pay Taxes in Both Countries?

US citizens generally remain subject to US tax rules on worldwide income, including qualifying income earned while living in the UK.

However, this does not mean that you will necessarily pay two full sets of taxes on the same income. The US tax system includes provisions such as the foreign tax credit and foreign earned income exclusion, which may reduce your US tax liability when you qualify.

The tax treatment of your income depends on its type, where it is earned, your residence and other relevant circumstances. UK tax obligations must also be considered separately.

For this reason, dual citizenship should not be treated as the sole determinant of your tax liability. You may need specialist tax advice if you earn income in both countries, own overseas financial accounts or plan to relocate.

See the IRS guidance for US citizens and resident aliens living abroad for further information.

Can Children Hold Both US and British Citizenship?

Yes. A child may be able to hold both US and British citizenship, depending on the rules governing each nationality and the child’s circumstances.

Children born in the UK

Being born in the UK does not automatically make every child a British citizen. Whether a child acquires British citizenship automatically depends on factors including their date of birth and a parent’s British citizenship or immigration status at the time of birth.

If the child does not acquire citizenship automatically, they may qualify to register as a British citizen under an applicable route.

Children born outside the UK

A child born outside the UK may acquire British citizenship automatically if a parent can pass on British citizenship under the relevant rules. In other circumstances, registration may be possible. US citizenship is determined separately under US law, including requirements concerning a US-citizen parent and their circumstances. A child who qualifies under both countries’ rules may be able to hold both nationalities.

Before applying to register a child as British, check whether they are already British automatically and whether they meet the requirements of the relevant route.