Frisco Limited is a company incorporated in the Cook Islands, and is used as a financing vehicle for a group of companies based in New Zealand. Grisco, which is also incorporated in the Cook Islands, is the sole nominated director of Frisco. With respect to the affairs of both Frisco and Grisco, the directors of Grisco act on instructions received from a New Zealand resident company (NZ Co) that is a member of the group, without discussing or considering those instructions. Both Frisco and Grisco are managed from the Cook Islands. Neither Frisco nor Grisco has an office in New Zealand. Determine if Frisco and Grisco are tax resident in New Zealand under the directors control test.