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.