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Parviz Malakouti-Fitzgerald, Esq.

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  • Writer's pictureParviz Malakouti-Fitzgerald, Esq.

"Core" vs. "Satellite" Residency Rights in Second Citizenship (Mobility Concepts)

This article is part of our series on mobility concept & strategy explainers.

When considering the rights and benefits of a given second citizenship, it’s prudent to separate residency rights given by a given citizenship into two categories, where they exist.

First category: "Core" residency rights are the right to live in THAT country. Core residency rights are not dependent on treaty, agreement or membership of the country in a union.

Example: You become a citizen of Croatia, so you then have the indefinite right of residency in Croatia.

Citizenship in Croatia offers core residency rights in Croatia.

Second category: "Satellite" residency rights are the right to live in ANOTHER country.

Example: You become a citizen of Croatia. Croatia is a member of the European Union (“EU”), so you have the right of residency in another EU country such as Czechia.

Therefore, Croatian citizenship offers core residency right in Croatia and satellite residency right in Czechia (as well as other EU countries).

Note: this strategy of using a mobility asset of one country in order to access another country is called springboarding.

Why the Difference Matters

One must distinguish these two types of residency rights because the satellite residency right is less robust of a residency right over time. Robustness i.e. strength of benefit is one of the four essential qualities of a given mobility asset, along with enterability, stayability, and immediacy of benefit.

Both core and satellite residency rights are vulnerable to the dissolution or division of the core country of citizenship, such has happened in Yugoslavia (1992), Czechoslovakia (1992), Sudan (2011), Austro-Hungary (1918) and countless other countries over the last century.

However, the satellite residency is vulnerable to at least four MORE future potential changes over time than the core residency right. In our example above, the satellite residency right could be diminished or even eviscerated by any one of:

1. Croatia's exit from the EU;

2. Czechia's exit from the EU;

3. A material change to Article 21 of the TFEU;

4. Czechia's potential unlawful restriction/prohibition of EU citizens' residency in Czechia.

Any of these four events occurring would end the Croatian's practical residency right in Czechia while leaving it untouched in Croatia.

As an aspiring multiple citizen, if you pursued citizenship in Croatia for the purpose of being able to live in Czechia, you’d have lost that satellite residency right even though you kept Croatian citizenship. Knowledge of this vulnerability would have been critical information when making your decision of where to pursue a given second citizenship.

You might look like this if you lose satellite residency right in a country you were counting on having residence access to

So, the phrase:

"Citizenship in an EU country offers the right of residency in any EU country"

while generally correct, offers a low definition view of the mobility asset and residency rights because it does not distinguish between the robustness of the residency right in the core jurisdiction versus in the satellite jurisdictions.

Viewing Other Mobility Assets Through This Lens

The same type of evaluation can, and should be made of any country that offers residency rights in another country whether by treaty, membership in a union, or otherwise.

A few additional examples of such unions are:

  • MERCOSUR in South America

  • CARICOM in the caribbean

  • The Common Travel Area (“CTA”) in the United Kingdom

When pursuing second citizenship, knowing the limitations and vulnerabilities of the benefit you’re seeking is critical to making an informed decision that will affect your family’s future trajectory for decades.

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