Facts

Dark Pty Ltd manufactures electrical appliances in Dubai, is incorporated in Dubai and all its shares are held by three individual residents in Sydney. Dark has an office in Sydney with twenty staff and is responsible for entering into sale contracts with Australian customers and for the marketing of Dark products world-wide. All directors of Dark are residents of Dubai and board meetings are generally held in Dubai.

Question

(i) Advise if Dark is or is not a resident for tax purposes, and (ii) how the trading income derived by Dark would be taxed in Australia.