A Comfy Chair
Actually if you dig a little deeper you will find that the ATO didn’t consider the SIN S/O basing an indefinite one because the said S/O’s would have to return to Australia for a promotion. The fact that many S/O’s may have owned property in Australia just reinforced in the ATO’s mind that any S/O taking a SIN base was only there for a finite period of time, therefore defining them as residents of Australia for tax purposes.