Why don't you simply set up your business in Malta? Normally a Maltese company that owns a Maltese company in Malta will only have like 5% total corp tax rate.. isn't there a way to make it 5% total here, no additional personal taxes for the Maltese resident?
Also, with your suggested Estonia setup, if you would spend 179 days a year operating that business from Estonia and have 183 days a year vacation in Malta, I'm thinking the classification that the Estonia business "would be taxed in Malta too" should not apply, though not sure - anyone thouhgts?
Tax Cow, what in the Estonia-Malta DTA is it you are thinking of, is there some︆ company tax residency clause in there, what does it say?
Anyhow off hand I don't︇ understand why Estonia is needed at all if you're going to Malta anyhow, which has︈ good structural options already.