A dupla residência das pessoas singulares no contexto da jurisprudência portuguesa

Abstract

This master's thesis deals with the problems arising from the dual residence in case of individuals, specifically in the Portuguese case. Thus, in this study, we analyze the situations in which dual residence can arise and how to resolve them, with the support of the Model Tax Convention on Income and on Capital, a vital instrument in the interpretation of the concept of dual residence, and the Tax Treaties, as well as the limitations of article 4 (2) of the Model Tax Convention on Income and on Capital. In this dissertation we focus on the response given to the problem of dual residence by national cases law, by analyzing various cases resolved by the Portuguese courts, as well as the changes to the CIRS motivated by the outcome of those.

Date of Award	5 Feb 2025
Original language	Portuguese
Awarding Institution	Universidade Católica Portuguesa
Supervisor	Leonardo João Santos (Supervisor)