yes, there is a declaration form CT2 that needs to be filed. Does not look so bad, to be honest. Wondering if I should just push back on the accountant.
CFC rules dont come into play here. The company would be deemed Maltese tax resident but non-domiciled in Malta. No tax is payable on foreign income which is not received in Malta and on capital gains arising outside Malta. At least this has been my understanding when having dealt with this jurisdiction.