Foreign company

I am going to set up a company in an overseas country which is not a Listed Country or Section 404 country according to the ATO web site:
http://ift.tt/1B0lKS7

If the only purpose of the company is to purchase properties in the overseas country and all the rental income earned is retained in the company, will the rents still be counted as part of my taxable income?

My accountant says no but I would like to get opinions from other experts.

Thanks in advance.

Foreign company