Doable with many proxies in tax-heaven who acts like the real company board, holds virtual meetings etc. They create all required paper trails which can comfortably bypass CFC restrictions.
Have been thinking about openning a company in Gibraltar. Best case would be 10% cooperate tax + 25 % tax on dividend. So you are a bit better of compared to a tax rate of 45%. More important would be a hedge against the regulatory risks.
As you said you need a managing director and maybe some employees. Have you done something like this or could you provide some more info's? Of course it should be legal!