Meijers Committee standing committee of experts on international immigration, refugee and criminal law not provide a relevant ground for distinguishing between citizens. The available information on recent deprivation decisions in Belgium, France and the Netherlands shows that most of the persons concerned were unable to renounce their other nationality (see paragrapah 4). According to official statistics 15% of the German dual nationals and 25% of the Dutch dual nationals have the nationality of countries which do not allow renunciation of their nationality (see paragraph 2). Finally, it can be argued that comparability should not be determined by looking at the presence or absence of a second nationality but by looking at the effective ties that exist between citizens and their country of nationality. From this perspective, a Dutch-Moroccan national who has lived most of his or her life in Morocco and is integrated into Moroccan society will not be comparable to a single Dutch national who acquired Dutch nationality at birth in the Netherlands and has always been resident in the Netherlands. This is in line with Article 7(1)(e) ECN which allows for the loss of nationality ex lege or at the initiative of the State Party if no genuine link exists between the State Party and the national habitually residing abroad.102 However, a Dutch-Moroccan national who is born and raised in the Netherlands will be in a relevantly similar situation and should therefore not be treated differently without an objective and reasonable justification when it comes to citizenship deprivation. If single and dual nationals are considered as being in relevantly similar situations, the respondent State Party must offer a justification for the difference in treatment. Under the ECHR, the margin of appreciation enjoyed by the state will depend on whether or not the ‘very weighty reasons’ test applies to differences in treatment between single and dual nationals. This margin will arguably be smaller if the person concerned cannot get rid of the second nationality as in that case the second nationality amounts to an immutable or inherent characteristic (see paragraph 6). In addition, Articles 18 TFEU and 21(2) EU Charter of Fundamental Rights may be applicable if the withdrawal of nationality results in the loss of EU citizenship. Differential treatment of born and naturalised citizens In some EU Member States (Belgium, France and Italy), only naturalised citizens can be deprived of their citizenship in relation to terrorist activities or, in the case of the UK, one of the grounds for deprivation applies only to naturalised citizens. Thus, the question arises whether the difference in treatment between naturalised and born citizens is compatible with the prohibition of discrimination. The discriminatory effect of this difference in treatment seems more obvious compared to the distinction between single and dual nationals, as the fact of being naturalised is very closely related to a person’s national origin. Paradoxically, however, the personal scope of deprivation regimes that apply only to naturalised citizens is far more limited. Under such regimes the sanction of deprivation cannot be applied to children of immigrants who acquired their nationality at birth. Where deprivation is not restricted to 102 Cp also the CJEU in Tjebbes, para 35 and J. Lepoutre, ‘When losing citizenship is fine’, Citizenship Studies 24:3 (2020), p. 339-354, DOI: 10.1080/13621025.2020.1733259. 20