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

Larissa Pereira Santos

doi:10.59403/1kvdc7d

August 31, 2025Deleted Journal

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

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Key Points

Certain domestic criteria may not establish treaty residence effectively, impacting tax obligations.
Individuals benefiting from preferential regimes, like NHR 2.0, may attain valid treaty residence status.
The assessment focuses on Article 4(1) of the OECD Model and its application in the Portuguese context.
Determining residence has significant implications for taxation and international agreements.

Implication

This analysis reveals treaty residence discrepancies among individuals under domestic law in Portugal, highlighting preferential tax regimes.

Abstract

This article examines whether all individuals considered residents by domestic law, or benefiting from preferential regimes, qualify for 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 as the NHR 2.0 can confer it.

Discussion

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Cite This Study

Larissa Pereira Santos (2025) studied this question.

synapsesocial.com/papers/68bb5f3e6d6d5674bcd03604 https://doi.org/10.59403/1kvdc7d

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

Key Points

Implication

Abstract

Discussion

Cite This Study

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

Key Points

Implication

Abstract

Discussion

Cite This Study

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