Others can correct me but, as far as I know, CRS will report to the country where the UBO resides. Maybe you should also include information about the company and what it does? Active Non-financial entities (NFEs) are treated differently when CRS comes to play. Also, does your friend reside in Georgia? If so, then there won't be any CRS reporting since Georgia does not participate in the CRS.
Did the EMI ever ask for any information about the UBO? any kind of CRS/AML forms? At this point, I won't say anything because I'm not sure if they'd be reporting or not but I'm sure that somebody else here can give you better insight. Either that or consult a tax expert which may be a smart thing to do if you are already "evading" tax via this Georgia structure.
....joking.
Neither Ukraine or Georgia have started CRS reporting. Georgia will start exchanging in 2024 and Ukraine in 2023. He can assume in worst case if EMI does CRS reporting it will report to Ukraine in 2023 date for year 2022.
P.s Ukraine maybe wiped out by 2023 or become Russian territory by Christmas so CRS reporting may occur earlier
