The issue present is regarding whether $$Daryl is an Australian Tax resident despite spending $260$ days overseas. $$Daryl is a resident under the Income Tax Assessment$($ITAA $1936)$ section $6(1),$ we need to apply TR $98/17$ the residency test. The primary test focuses on whether an individual resides in Australia.$$Daryl is Australian tax resident for the purpose of income tax he is employed by Australia airway. Daryl spends $260$ days of the year overseas as a long$-$haul pilot, which suggests a strong connection to international locations $,$ his absence is due his work $,$However, he spends the remaining days in Australia managing his olive oil import business. The fact that he is actively engaged in a business in Australia strengthens his ties to the country.$$

Additionally, Daryl's decision to sell his investment property in St Kilda during the $2023-24$ tax year indicates ongoing connections to Australia, as ownership of property is a significant factor in determining residency.$$in the case of Joachim v$.$ FCT$,$ the High Court of Australia examined the residency status of an individual for tax purposes. The court considered the facts surrounding Joachim's living arrangements, his connections to Australia, and his time spent overseas. It emphasized that residency is determined by the totality of circumstances, including physical presence, intention, and the nature of ties to Australia.$$Darly is a resident for tax purpose and is taxed on his worldwide income $.$