This study comes in the aftermath of a stable set of cases of the STA, which considers as illegal the rule present in art. 16º, n.º2 of the "CIRS" due to the infringement of the autonomous concept of residence enshrined in the DTC's. Based on a comprehensive analysis of the dual residence of individuals in both internal, european and international dimension, the author illustrates some of the deficits and inconveniences of that line of reasoning, suggesting some solutions that could help to overcome the identified problems.
|Number of pages||39|
|Journal||Revista de Finanças Públicas e Direito Fiscal|
|Publication status||Published - 2011|
- Dual residence
- Deemed residence of individuals
- Double tax conventions