Barter Pty Ltd is incorporated in Japan, where the company manages a business of leasing commercial properties. The company has five directors - three of the directors reside in Australia and two reside in Japan. Due to the pandemic, many of the conferences operate via Zoom, and occasionally the directors meet in Japan for board meetings. The directors in Australia make all the high-level decision making, while the directors in Japan silently confer and do not actively contribute to the decision making.

Required: Consider whether Barter Pty Ltd is an Australian tax resident in these facts and the source of Barter Pty Ltds income. Please support your answer with relevant legislation and case law.