How about: open a Cyprus company, and pay a monthly salary from it (and social insurance contributions) but not actually trade with it. Motivation: 60d tax residence (this requires either Cyprus employment or a Cyprus company to be maintained year-round), and also rights to healthcare via the social insurance contributions.
Meanwhile, open a Singapore/UAE company or some other favourable offshore structure (need to investigate this further but e.g. Singapore requires a local nominee director and apparently Cyprus are quite lax concerning CFC, I've heard that one may pay 0%).
Upsides: Optionality. Also one avoids ATAD, and it's quite flexible in that the CyprusCo could be closed down and the SgCo used partially as a way to move to Singapore.
Meanwhile, open a Singapore/UAE company or some other favourable offshore structure (need to investigate this further but e.g. Singapore requires a local nominee director and apparently Cyprus are quite lax concerning CFC, I've heard that one may pay 0%).
Upsides: Optionality. Also one avoids ATAD, and it's quite flexible in that the CyprusCo could be closed down and the SgCo used partially as a way to move to Singapore.