This article provides an examination of the Australian income tax implications that may arise if the Commissioner is successful in applying TR 2018/5 such that a foreign incorporated company is considered an Australian tax resident on the basis of central management and control. Many of the foreign incorporated companies caught by TR 2018/5 will also be regarded as resident in their country of incorporation and thus a “dual resident”. Although Australia has a tax treaty network that is available in some cases to potentially resolve the issue of dual residence for treaty purposes, a range of domestic tax law implications will arise when a foreign incorporated company is a dual resident. This article highlights the Australian tax issues faced by a dual resident, including the importance of the relationship between tax treaties and domestic law in addressing these issues.