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Brexit: UK nationals in the EU and EU nationals in the UK

UK nationals in the EU and EU nationals in the UK

The European Union (EU) has rules allowing the free movement of nationals of the European Economic Area (EEA) and Switzerland. These rules allow EEA nationals to move between EEA countries with their family members and live, work, study or start businesses in these countries.


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Brexit: UK nationals in the EU and EU nationals in the UK

This guide has been written prior to any definitive statement from the UK Government on the implications of Brexit on nationals in the UK and UK nationals in the EU/EEA.

The UK Government has indicated that it will not permit free movement in its current form after the UK leaves the EU. This means that there will be some form of restrictions on the free movement of EEA nationals to the UK post Brexit and they may have no free movement rights at all. The freedoms UK nationals enjoy in other EEA states may also be restricted on the basis of reciprocal treatment. It is expected, however, that EEA and Swiss nationals in the UK and UK nationals in other EEA states who are already exercising these rights will be protected. The exact nature of the protection and the cut-off date from which it will apply will only become clear as the exit agreement between the UK and EU is negotiated.

As EEA nationals have historically been able to exercise the right to free movement in the UK without necessarily obtaining any documentation, KPMG’s current view is that people affected will need to make some kind of application to prove they exercised free movement rights before the relevant cut-off date. The nature of that application and the value that it will provide an individual and their dependants will depend on the final terms of Brexit.

Some EU nationals in the UK will already have rights which they can evidence now. The free movement rules include a right to permanent residence after five years in a host country i.e. where the individual permanently resides. People who qualify for this can apply to their host country for a document certifying permanent residence. In addition, each individual EU country has its own rules about obtaining citizenship.

An individual’s immigration position can be complicated. One consideration in whether to apply for citizenship of a country is whether the individual’s home country (most often their country of birth) will allow dual citizenship.

Our guide provides some initial information on each of the 30 EEA member states and the UK on their current position on dual citizenship. It is important to note that we provide confirmation of whether dual citizenship is allowed; obtaining dual citizenship may have an impact on other matters such as tax status. Therefore, this is a guide only and individual advice on the wider implications of dual citizenship should be sought.

This document contains one flowchart to help EEA and Swiss nationals and their family members assess their rights in the UK and another to help UK nationals and their family members assess their rights in their host EEA state. It also outlines the headline requirements for citizenship of the countries in the EEA.

© 2020 KPMG Central Services, a Belgian Economic Interest Grouping ("ESV/GIE") and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved. 

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