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
- Larissa Pereira Santos (ORCID: https://orcid.org/0000-0002-9419-0946)
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