If there is sufficient economic substance it will most likely be exempt in the shareholders home country. This will depend on the CFC rules of said country as well as a DTA between the two countries.
In OPs case setting up economic substance will most likely cost more than the taxes saved.
OP, it will be worth your while reading up on CFC rules as these are essentially what @xzars are referring to. Moving offshore has become considerably more complicated since governments have tightened up these rules.