The majority state-owned (well̃, >30% federal state and >20% city) Frankfurt airport company has a holding... sorry, "management" company in Malta. Maybe they are doing just enough business in Malta to hold up to scrutiny. Most are based on no one looking too closely. But it's not a very meaningful difference. Heck, maybe I'd occasionally fly to Malta and work from there if that helped to "optimize" taxes like the big boys.