this seems more a matter of residence of the company (Place of Effective Management criteria).
i believe you are mixing 3 concepts
1) residence of the company (based on internal legislation and on DTAs)
2) presence of permanent establishment (again internal legislation and specific DTA)
3)
CFC which concerns usually a passive income company that becomes disregarded for tax purposes in the owner's taxable base
as far as i know, georgia has no CFC legislation in place. While other points 1) and 2) require a case by case analysis