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ABC Ltd is a container shipping company that is incorporated in Singapore. The company has three directors, all resident in Singapore. An Australian resident holds

ABC Ltd is a container shipping company that is incorporated in Singapore. The company has three directors, all resident in Singapore. An Australian resident holds the majority of shares in ABC Ltd. The company prepares shipping contracts for freight between Australia, New Zealand and China. These contracts are all made by the Australian shareholder. The Australian shareholder has the power to remove any or all of the three directors. In fact, the three directors have little or no knowledge of the business of the company. All high-level decisions are made by the Australian shareholder and any resolution by the company has no effect unless it has his approval. Is ABC Ltd a resident of Australia for tax purposes?

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