Securing Polish citizenship is rarely the end of the story. Once the certificate is issued and the passport collected, a practical question follows: what does holding two nationalities actually mean day to day? Military obligations, taxation, which passport to show at which border — these are the areas where rumour travels faster than the statute. Here is what Polish law actually provides.
I. The Polish principle: before Poland, you are Polish and nothing else
Polish law permits dual nationality, but treats it in a distinctive way. The Polish Citizenship Act (ustawa o obywatelstwie polskim) of 2 April 2009 sets out two complementary rules in Article 3.
- A Polish citizen who simultaneously holds the nationality of another State has, as regards the Republic of Poland, exactly the same rights and the same obligations as a person holding Polish citizenship alone.
- Conversely, that citizen may not effectively invoke the second nationality before Polish authorities, nor the rights and obligations flowing from it.
In other words, Poland does not ask you to renounce your existing nationality — but it declines to take any account of it. Before a Polish authority, a Polish court or a Polish border officer, you are a Polish citizen, full stop. That single principle explains nearly every practical consequence that follows.
II. Military service: the exemption for dual nationals living abroad
This is the most common concern, particularly among parents of young adults. The Homeland Defence Act (ustawa o obronie Ojczyzny) of 11 March 2022 subjects Polish citizens in principle to the defence obligation, according to age and state of health.
Article 3, paragraph 1, of that Act of 11 March 2022, however, contains an exception: a Polish citizen who also holds the nationality of another State is not subject to the defence obligation if he or she permanently resides outside Poland (“stale zamieszkuje poza granicami Rzeczypospolitej Polskiej”). For a family settled in Israel, France, the United Kingdom or North America, this is the ordinary case.
This exemption has no effect in Israel: an Israeli citizen with dual nationality remains bound by the Security Service Law (Section 1, definition of “person liable for service”) and is treated as an Israeli for the purposes of Israeli law (Citizenship Law, Section 14(b)).
Two qualifications matter:
- The exemption rests on genuine permanent residence abroad, not on merely holding a second passport. The notion of permanent residence (“stale zamieszkuje”) is assessed case by case.
- It is assessed over time: settling durably in Poland changes the position, which is then examined under the general rules.
Polish law therefore creates no new military obligation for a family that lives and intends to remain abroad. Cases of residence genuinely split between two countries deserve closer review, since the notion of permanent residence becomes delicate there.
III. Taxation: nationality is not tax residence
The second recurring worry is that becoming Polish will expose the holder to Polish taxation. That is not how tax law operates.
Under Polish law, an individual’s liability turns on tax residence (rezydencja podatkowa), assessed by factual criteria: the length of presence on Polish territory during the year, and the location of the centre of vital interests (ośrodek interesów życiowych) — that is, of personal and economic ties. Nationality is not in itself a criterion of tax residence.
Nationality plays only a marginal role, and only where two States each treat the same person as resident: tax treaties built on the OECD model then apply a sequence of tie-breaker tests in which nationality ranks last, after the permanent home, the closest personal and economic relations, and habitual abode.
For someone who lives, works and earns in another country, obtaining a Polish passport does not of itself shift tax residence. The position changes if Polish-source income arises, or if the centre of life genuinely moves — questions that call for their own tax analysis, separate from the citizenship file.
IV. Passports: which document at which border
Here the principle laid down in Article 3 of the 2009 Act produces its most visible effect. According to the practice of the Polish authorities (to be checked on the official websites), a person holding several nationalities crosses borders on the travel document issued by the State whose nationality is being relied upon, and must present a valid Polish document if he or she wishes to be treated as a Polish citizen at the control point.
The consequence is counter-intuitive but coherent: presenting only a foreign passport on entry into Poland leads to being treated under the rules applicable to nationals of that State — including, for a third country, the corresponding limits on length of stay. A Polish passport is not a matter of convenience: in practice it is the usual way to assert a nationality that Poland will not infer from a foreign document.
In practice, a dual-national family travels with both passports, each used at the border of the State that issued it. The rules of the other State of nationality on the use of its own travel documents apply independently; for Israel, Section 2A of the Passports Law (5712-1952) requires an Israeli citizen to present an Israeli passport on entering and leaving Israel.
V. The other side: dual nationality is generally permitted
The question naturally arises in reverse: does acquiring Polish citizenship endanger the nationality already held? As a general matter, most of the legal systems concerned — Israel and France among them — do not treat the voluntary acquisition of a foreign nationality as an automatic ground for losing the original one, and permit dual nationality.
This nevertheless warrants case-by-case verification, particularly where the person holds public office, an elected mandate or certain sensitive positions, for which specific incompatibility rules may exist. That is not a question of Polish law: it is examined under the law of the State concerned.
Conclusion – Why work with a lawyer on Polish citizenship matters?
Polish dual nationality is less a status than a set of consequences to anticipate. Article 3 of the 2009 Act lays down the principle that the second nationality is disregarded; the military exemption for dual nationals living abroad derives, for its part, from Article 3 of the 2022 Homeland Defence Act. Nationality is irrelevant for tax purposes, and one should travel on the right document. Addressing these points early — at the confirmation-of-citizenship stage rather than years later — avoids border difficulties and badly framed tax questions.
The firm assists international and Israeli families in assembling and following up these files, working with correspondents in Poland for local procedural steps, and refers clients to the appropriate advisers where a question falls under tax law or the law of the other State of nationality.
It is with this in mind that the Firm ABITBOL & ASSOCIES, drawing on its expertise in nationality law and private international law, assists its clients at every stage of assembling and following up their Polish citizenship file, and in anticipating the practical consequences of dual nationality. Our lawyers ensure that your interests are protected and that every step is taken in complete security.
Abitbol & Associés
Lawyers & Notaries · Jerusalem — Paris
13 Shimon Ben Shetah St., 9414713
Tel. +972 (0)2 595 63 45
Fax +972 (0)2 591 63 26
13 Avenue Hubert Germain, 75116
Tel. +33 (0)1 78 90 03 73
Fax +33 (0)1 77 74 63 99
