Thank you for sharing your experience with us. It seems you've spoken with all maltese accountants.
If Malta allows direct payment to the UBO a quite interesting option is to have a Belize corp as holding since
privacy is achieved.
CFC has been introduced this year, therefore it is not surprising that this did not interest anyone before. But anyway a threshold for
active income is quite high, so if you have 1 resident + holding and 1
offshore company you can optimize your taxes quite effectively.
If I used to lean towards Cyprus, now Malta looks much more attractive to me. If you will be speaking with accountants next time, can you please ask if it is possible to get a
tax residency certificate without actually living there for 183 days?