Relocating to Malta as a trader owning a tax-free offshore company in let's say Seychelles. Things like that won't work out anymore because Malta, Cyprus etc. apply to the CFC rules since last year, too! If you don't have the right setup (Malta LTD + UK Holding or Malta LTD + Cyprus Holding for example) you won't be able to save any taxes, but actually commit tax evasion in Malta instead.
Not fully accurate, there are exceptions:
"The CFC rule shall not find application in relation to an entity or permanent establishment:
- with accounting profits of no more than EUR 750,000 and non-trading income of no more than EUR 75,000; or
- of which the accounting profits amount to no more that 10% of its operating costs in the tax period."
EU ATAD implemented into Maltese domestic law
Malta has implemented the Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market. Learn more...
www2.deloitte.com
So as long as the company doesn't generate profits of more than 750K EUR and non-trading income of more than 75K EUR it falls outside CFC scope.