You are right, but i can share some experience:
- so far, i have not seen any bank actually ask for tax residence certificate. Some banks are fine with jsut simple self-certification form (i was always wondering what would happen if one just put any non-crs country info there?). Some go further and ask for residence permit and address proof. My experience does not cover all cases, of course, but it's quite considerable. I'm more interested to see what exactly happens when Tax office of Malta receives via CRS information on, say, someone who has obtained Malta special tax status under Global residence program (i also must point out that of all numerous Malta residence programs only GRP is specifically tax-oriented one) and claimed somewhere else to be tax resident of Malta, but actually isn't.
- I know people who, having maltese residence, did the following: had someone live in their apartment occasionally (to show spending on utility bills), have someone trusted use their maltese bank card in Malta, joined gym, and tax certificated was received without any questions with actual time spent on Malta barely being two weeks in a year.
Good to know and yes that would certainly work on the Maltese side. In general i would not worry about the Maltese side too much except for checking that one fact if you have to stay a certain time (no matter which program) to actually get the certificate. Your solution i would certainly believe to work without a problem as being a Maltese resident and seeing how things work here.
I would rather worry about the origin / citizenship IRS in case you are western European. E.g. spending 100 days in Germany, 7 days in Malta under the program will not fly with Germany even if Malta gives you the certificate as they don't care about the foreign tax certificate or 183 days. All just indicators for them.
Would probably also be careful with France etc. In general European flight passenger data sharing etc. Again Malta will not check this.