CFC rules are not the issue. It is some sort of internet myth that CFC rules are that big thing and if a country doesn’t have them, you can do what you want. Nope, not true. They are only a “catch all” rule, “if you escaped all other rules and you’re STILL saving taxes, then this is how we’re going to screw you.”
It is also not an issue per se if he has clients in Georgia, though that of course makes it even more obvious.
But the effective place of management is the issue. Both in terms of corporate tax residency and permanent establishment.︀
In a country like Georgia, you can live tax-free off dividends paid by a company︁ that you don’t manage from Georgia. But if your a*s is in Georgia and everything︂ you do is done in Georgia, it does not matter where the company is registered︃ or if Georgia has CFC rules. It also doesn’t matter where the customers are located︄ - that’s only relevant when you don’t have PE:
“Legal entities incorporated abroad are normally︅ treated as foreign tax residents (“nonresidents”) and are taxable on income from Georgian sources or︆ income from performing business activities thorough their permanent establishment in Georgia.”
https://www2.deloitte.com/content/d...o Taxation and Investment︇ in Georgia 2016.pdf
Of course they probably don’t enforce that for foreigners because they’re happy︈ they bring some money into the country. But that doesn’t mean it’s what the law︉ says.