Armin Ronacher's Thoughts and Writings

On Countries, Citizenships, Residence and Paying Taxes

written on Sunday, August 9, 2015

Like many software engineers my life involved moving from one country to another for work. Since that moment this whole concept of relocation fascinated me because almost everyone in my circle of friends ended up in a place far from where they came but their stories were different. I learned that the topic of relocation and immigration is a very complex and diverse one. How widely different the experience can be for different people! Most interesting about this however is how little people not affected by this understand the complexities of being an immigrant in another country.

While my experience of moving to another country was the easiest imaginable, it was harder for my wife. How different immigration can be is hard to imagine from the outside.

Since immigration is a big topic again I figured I might share some of my experience on the topic to shed some light on how all that stuff actually works.

The Basics

The most important part is to understand the legal basis for pretty much all topics related to entering and leaving a country and the permits. This is surprisingly complex because of the huge variety of different terms for related topics.

Citizenship is typically what you get at birth and it makes you the citizen of a certain country. In the majority of countries being a citizen gives you certain rights but also obligations. For instance in Austria citizenship gives you the right to vote, but you are required to defend your country. Citizenship also almost always gives you the right to live in a country though there might be further requirements.
Multiple Citizenships
This refers to the idea of holding two (or more) active citizenships. This is one of the more complex topics because of how different countries approach this. On the one hand are countries like Austria which have the concept of dual citizenships but make it very hard to hold multiple. On the other there are countries like the US which do not recognize other citizenships at all but will not prevent you from holding multiple. Lastly there are countries which outlaw multiple citizenships altogether.
If you are not a citizen of a country you might need a visa to enter or leave a country. Visas in itself however do not necessarily give you the right to actually be in a country. A good example for that would be a person who immigrates into a European country for work from a country with a passport that requires you to have a visa. In that case you need a visa to cross the border and then you need a permit to stay / permit to work.
Permits come in different flavours and not all countries have the same approach to them. In most countries there are permits to stay and separate permits to work and sometimes there are residence permits which work differently. In Austria for instance there are permits called “Aufenthaltstitel” which literally translates to “entitlement for stay” which also usually comes with an indication if you are allowed to become part of the workforce or not. For instance a family member permit gives you the right to work whereas a permit for stay for students will only give you limited permissions for working.

Passports are travel documents and means to identify yourself internationally. As of a few years ago any person travelling will need one of those which includes little children. Interestingly however passports are a lot more complex than you might think because they are not directly linked to citizenship. More about this later.

A passport gets you across a border and in many cases can act as an universally accepted way to proof something about yourself. For most states in the world the passports follow a generally accepted format which makes them very convenient and they are on of the few documents you never need to translate. Because of this, they will become your best friend when you are not at home though they are by no means the only document you need to reside in another country.

Relationship Citizenship and Passport

Most people would assume that having a passport of one country makes you a citizen thereof. That however is not at all correct. There are different reasons for this and I can't go into all here. The biggest reason why you might have a passport of a country you are not a citizen of is because you are a stateless person.

For most people in the world once they hold a citizenship they cannot become stateless. The reason for this is that there are international treaties where if ratified in a country you cannot lose your citizenship unless you acquire another one. There are some countries where this is not the case. The United States being the most popular of them. A US national can give up their US citizenship and become a stateless person this way. The reason this works is because you do not need to be a US citizen to be a US national. For instance people born in American Samoa are US nationals but they are not US citizens. This is also the part where citizenship and nationality becomes unclear. A person born in American Samoa will for all intents and purposes be seen as a US citizen as their passport will indicate that they have US nationality.

On the other hand there are many stateless people living in Estona and Lativa who are officially stateless. The reason for this is that they are Russian speaking and are either not entitled to Estonian or Latvian citizenship or have no interest in applying for one. They are issued a special passport for stateless people which however some some special powers an Estonian passport does not have: they can travel to Russia visa free.

How Do I Migrate?

This for many is the million dollar question. How can I immigrate in a foreign country? Generally this question heavily depends on your own citizenship and the laws of the country you want to become a resident of.

Here are the most common ways to immigrate:

Freedom of Movement

Sometimes you are entitled just like that to live in another country like a citizen of that country would be. This for instance is the case within the European Union. If you are German but you feel like living in the Czech Republic, you can do so. Just head there and you're done. That's not entirely true, you still need to do some paper work in some cases (like registering etc.), but there is no rule that prevents you.

This is by far the easiest route but it's restricted to a certain population of the world, and there is good chance you as a reader are not in that group.

Marry a Citizen

Marriage is still the best way to get a permit of residence and it's becoming an even better by the day because the requirements are so stict nowadays. However marriage does not immediately give you residence and most people will probably have noticed that. As an example in order for me and my wife (who is not Austrian) to legally live together with our child in Austria we need to have household income of 17.500 EUR per year after taxes. That does not sound like a lot, but for many people it's not the easiest thing to show, especially because those earnings need to exist regardless of the outcome of your residence application. For most people this means showing that you have that much in cash available as you probably do not live in the country yet to demonstrate a regular income through paychecks.

In the United Kingdom the income requirement is currently 18.600 GBP / year and you need to show income for 2.5 years. Which means that if you want to show it in savings, you need to have at least 62.500 GBP on an account somewhere.

Be Exceptional
The only other way to immigrate is typically to be exceptional. In most countries this is either by being rich enough to invest into the country and get residence or citizenship in the process or by being extraordinary intelligent or in demand. This works well for engineers because engineers are in demand in almost all places. However that is no guarantee yet, as in most countries visas and permits are restricted by numbers and there is a certain amount of luck requirement to get one.
Become a Citizen
Most people cannot become a citizen from one day to another, but sometimes they can. In that case that is the way to go. Typically this is done by a prior claim to citizenship that you forgot about (for instance to be born to a parent with a certain citizenship). This most of the time is only possible for as long as you did not turn 18 yet.
Claim Asylum
In certain situations you might be getting away with claiming asylum. Pretty sure the chances that you are a reader of this blog and you quality for this route are very dim. Asylum is restricted to people who come from situations where their life is in danger.

The Illegal Route

Many people I met over the years just never legally immigrated somewhere. That however does not mean that they are illegally in the country. It can also mean that they just never immigrated to begin with and just hop from country to country. They are there as submarines either by pretending to be tourists and regularly changing the place of living.

This is a bit different from the traditional method of not crossing the border much which many migrant workers do. This however can turn terrible the moment someone catches you. Overstaying your permitted time in Schengen for instance will lock you out for 5 years from almost the entire European Union.

This entry was tagged personal, politics and thoughts