Turns out, unsurprisingly, the ATO are all over this concept. Any entities overseas that you control, the business profits are subject to Aussie tax
Grok:
As an Australian tax resident (whether an individual, company, trust, or other entity), you are generally taxed on your worldwide income. This means all income you earn or derive from sources anywhere in the world is included in your assessable income for Australian tax purposes, regardless of where it originates or whether it’s remitted to Australia. This includes employment income, business profits, investment returns, capital gains, and other sources. Foreign income is converted to Australian dollars using applicable exchange rates, and you must report it in your annual tax return.
However, when it comes to income from a foreign company that you own or control abroad, special anti-avoidance rules come into play to prevent deferral of tax by parking profits offshore. These are primarily the Controlled Foreign Company (CFC) rules, which attribute (or “impute”) certain income from the foreign company back to you as if it were your own, even if the company hasn’t distributed the profits to you. This ensures that passive or low-taxed income isn’t sheltered in foreign entities you control. The rules apply to both individual residents and Australian resident companies that hold interests in foreign entities.
