 The debate over voting rights, in particular, is complex and covers both external (extending voting rights to nonresident citizens) and internal voting (expanding the franchise to resident non-citizens). Theorists with sympathies to the social membership thesis (arguing that residence over time in a specific territory is the key to membership in a society) or to the stakeholder conception of citizenship usually consider that long-term residence in a country should be the basis for the allocation of democratic rights. The argument may cover not only migrants who qualify for permanent resident status, but also those who have entered illegally in the country (Carens 2010b, 2013) as well as temporary migrants, in particular ‘guest workers’ who are often denied any access to citizenship (Lenard 2015). On this view, safety from deportation and the entitlement to the state’s protection when abroad is what distinguishes citizens from resident noncitizens. Citizenship rights are understood as extra-territorial (“they follow the citizen rather than the territory”) while voting rights are best understood as territorial (Lenard 2015,  131).[27] 