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 cover︀ all cases, of course, but it's quite considerable. I'm more interested to see what exactly︁ happens when Tax office of Malta receives via CRS information on, say, someone who has︂ obtained Malta special tax status under Global residence program (i also must point out that︃ of all numerous Malta residence programs only GRP is specifically tax-oriented one) and claimed somewhere︄ 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 show︆ spending on utility bills), have someone trusted use their maltese bank card in Malta, joined︇ gym, and tax certificated was received without any questions with actual time spent on Malta︈ barely being two weeks in a year.