Stock Tours Pty Ltd is a company incorporated in New York, USA. Stock Tours Pty Ltds business involves providing guided tours of Wall Street in New York. Stock Tours Pty Ltd has no trading activities or sales in Australia. James Cash, an Australian tax resident, owns all the shares in Stock Tours Pty Ltd. The directors of Stock Tours Pty Ltd regularly meet in Brisbane, Australia, where the power of management is exercised. In relation to the above facts, which one of the following statements is the most correct?

Select one:

1. As central management and control is exercised in Australia and the voting power is controlled by Australian residents, Stock Tours Pty Ltd will be considered to be a resident for Australian taxation purposes.

2. As Stock Tours Pty Ltd is not incorporated in Australia, it is not possible for it to be a resident for Australian tax purposes.

3. Stock Tours Pty Ltd ordinarily resides in Australia and is therefore a resident for Australian taxation purposes.

4. As Stock Tours Pty Ltds controlling shareholder is an Australian tax resident, Stock Tours Pty Ltd, for that reason alone, will be regarded as an Australian tax resident.

5. As Stock Tours Pty Ltd is not conducting business in Australia, it will be regarded as a resident for Australian taxation purposes.