Residence under Article 4(1) of the OECD Model: Deemed Criteria, Preferential Tax Regimes and the Portuguese Case Study

This article examines whether all individuals considered residents by domestic law, or benefiting from preferential regimes, qualify for treaty residence under article 4(1) of the OECD Model. Using Portugal as a case study, it concludes that certain domestic criteria may be insufficient to establish treaty residence, while preferential regimes such as the NHR 2.0 can confer it.

Authors

Publication Details

Journal
Bulletin for international taxation
Published
2025-08-31
DOI
https://doi.org/10.59403/1kvdc7d
Primary Topic
Taxation and Legal Issues
Type
article
Field-Weighted Citation Impact
0.00
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article

Residence under Article 4(1) of the OECD Model: Deemed Criteria, Preferential Tax Regimes and the Portuguese Case Study

Larissa Pereira Santos
Bulletin for international taxation
Taxation and Legal Issues
article

Residence under Article 4(1) of the OECD Model: Deemed Criteria, Preferential Tax Regimes and the Portuguese Case Study

Larissa Pereira Santos
article en

Abstract

This article examines whether all individuals considered residents by domestic law, or benefiting from preferential regimes, qualify for treaty residence under article 4(1) of the OECD Model. Using Portugal as a case study, it concludes that certain domestic criteria may be insufficient to establish treaty residence, while preferential regimes such as the NHR 2.0 can confer it.

Bulletin for international taxationVol. 79(9/10)
Openalex Percentile: Top 65%
Taxation and Legal Issues
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Residence under Article 4(1) of the OECD Model: Deemed Criteria, Preferential Tax Regimes and the Portuguese Case Study — Larissa Pereira Santos · Bulletin for international taxation (2025) | TGRS Research Map | TGRS