While I hope Brexit will be stopped, I'm expecting and preparing for the worst. So, with only two months before the EU approval process would need to start and Brexidiots in charge on the UK side, I'm expecting the UK to 'crash out' on 29 March 2019, without agreeing the terms of withdrawal (let alone any deal on future trade).
As a self-employed lawyer, there's both the professional and personal angles to consider.
As a self-employed lawyer, there's both the professional and personal angles to consider.
Professionally, my UK legal qualifications will no longer be recognised in the EEA. So, I need to get qualified in an EEA state in order to continue credibly advising my UK clients on their EEA business activities, and advise my EEA clients on their UK activities. The only realistic option is adding an Irish legal practising certificate and consulting through an Irish law firm. Ireland will be the only truly common law jurisdiction left in the EEA, as both Malta and Cyprus have a mix of civil and common law, and it's laws are still very similar to the law in England and Wales.
That rather costly process is well underway, as previously explained.
That rather costly process is well underway, as previously explained.
But that doesn't mean I personally have the right to live in Ireland, of course. So the question remains whether I could replace my UK right to live and work anywhere in the EEA by means of citizenship in the remaining 27 EU member states or one of the 3 EEA member state (Norway, Iceland or Liechtenstein) - without losing my UK and Australian passports?
As the EU Parliament research reveals, there are differing national approaches to being or becoming a citizen of the various EU member states. But the key issue is whether your favoured country allows you to retain your UK (or other) citizenship. For instance, the following countries would require you to give up your UK citizenship in order to become a citizen there:
- Austria
- Bulgaria
- Croatia
- Czech Republic
- Denmark
- Estonia
- Germany
- Latvia
- Lithuania
- Netherlands
- Slovenia
- Spain
So there goes any chance of moving to, say, Barcelona or Mallorca without first becoming a citizen elsewhere in the EEA.
Unfortunately, given the dual nationality of my spouse and children, of the 3 additional EEA countries, only Norway requires you to renounce your other citizenship(s) if you wish to become a citizen there (i.e. rather than automatically having it by birth etc) - although a change in the law has just been submitted to the Norwegian parliament.
Otherwise, the options are as follows (excluding those where the EU research says you can still later lose your citizenship by living somewhere else):
BelgiumCyprus- Finland
France- Greece
- Hungary
Ireland- Italy
- Luxembourg
Malta- Poland
- Portugal
- Romania
- Slovakia
Sweden
- Iceland
- Liechtenstein
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