Exploring Atypical Citizenship Deprivation and Spillover Effects
regulations for Taiwanese citizens in terms of visa, temporary stay and travel.58
Therefore, mis-recognition may lead to difficulties in this regard. One of the most
commonly mentioned impacts of citizenship deprivation is the possible
deportation of a dual citizen to their second country if they lose citizenship in their
country of residence,59 which in the case of overseas Taiwanese, the loss of rights
may result in deportation to China. In the next section, using the case of Taiwanese
citizenship, this author explores the scenario of Taiwanese citizenship in foreign
lands by examining the influences of two examples of the denial of Taiwanese
citizenship within Liu and Others v Norway60 and Liu v Poland.61 In the first case,
the argument draws directly on the right to identity in relation to atypical
citizenship deprivation, while the second case, which focuses on other rights
associated with nationality recognition in the context of an extradition case,
illustrates the spillover effects of sovereignty issues on contested citizenship.
IV
TAIWANESE CITIZENSHIP IN THE INTERNATIONAL SETTING: RIGHT TO
TAIWANESE IDENTITY
Statehood (or its lack of) can significantly impact the citizenship rights of a people,
especially on the international stage. This affects Taiwanese citizens as they travel
or relocate abroad, creating uncertainty surrounding their citizenship status. Some
countries, such as Morocco and Georgia, do not recognise Taiwanese passports as
valid travel documents, barring Taiwanese citizens from using such passports and
requiring different travel documents. However, even in places where Taiwanese
passports are accepted as legitimate or genuine travel documents, individuals are
often labelled as ‘Chinese’, leading to identity conflicts for Taiwanese citizens.
Cases illustrating this can be found in Germany, France, Iceland, and Norway.62
Taiwan’s international relations further complicate the citizenship status of
Taiwanese citizens in foreign countries. Only 12 states officially recognise the
ROC as a sovereign nation as of 2025.63 However, in practice, most states do not
categorise Taiwanese citizens as Chinese, recognising that they are not under the
governance of the Chinese Government. This partial recognition involves
accepting Taiwanese passports while not formally acknowledging Taiwan as a
sovereign state. Consequently, the citizenship status of Taiwanese citizens in these
states is legally and politically ambiguous. For instance, the UK Government does
58
59
60
61
62
63
See ‘The Henley Passport Index 2025 Global Ranking’, (Report, Henley & Partners, 2025).
Holders of Taiwanese passports enjoy visa-free access to 136 destinations, compared to 82
for holders of Chinese passports.
Matthew J Gibney, ‘Denationalisation and Discrimination’ (2020) 46(12) Journal of Ethnic
and Migration Studies 2551.
Liu and Others v Norway (n 8).
Liu v Poland (n 9).
The relevant discussions can be found in: Chen Jing-Han, ‘Contested Citizenship and
Statelessness in Question: An Analysis of Cases of Overseas Taiwanese People and Tibetan
Exiles in Taiwan’ (PhD Thesis, University of Edinburgh, 2023) ch 4.
‘Bang jiao guo’ [‘Diplomatic allies’], Ministry of Foreign Affairs, Republic of China (Taiwan)
(Web
Page,
12
February
2026)
<https://www.mofa.gov.tw/AlliesIndex.aspx?n=0757912EB2F1C601&sms=26470E539B6F
A395>, archived at <perma.cc/8HH2-3G8C>.
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