Yes that’s what I’m doing. I’m physically locating to a country with no CFC rules (Thailand).Even if someone actually implements a structure that has the licensing option, my question is what about UBO and bank accounts. Ultimately I will be the UBO and funds will end up in an account controlled either directly by me or through a trust. That means the licensing aspect will be of no use, and the caymans company will also come under CFC rules. After CFC, economic substance and CRS, accountants aren't just ready to work with offshores. Its very difficult now and race against time, one by one all the countries will get into CRS. The only option is to physically relocate.
They probably will implement them one day but by then yes someone will have worked out how to legally by pass them. Governments will always be one step behind in my humble opinion.
(Also Nevis doesn’t have Economic Substance reporting).