As I read it, there is NO requirement that the 'garage' have any receptacles. Even if it does, the receptacles don't count as the required outlets.
201.8(A)(6) discussed GFI requirements 'where the receptacle serves the counter area.'
I say : the code can't have it both ways. Perhaps this should be submitted for clairification in the next code edition.
I have problems with several NEC kitchen requirements. Perhaps the appropriate committee ought to leave the kitchen to their wives :-).
Imagine a counter whose entire length fronts an appliance garage- where the appliances sit, already plugged into some plugmold, just waiting to be pulled out and used. Since these receptacles are not counted toward the required receptacles, you are now required to place additional receptacles above the appliance garage. Now, since the garage receptacles are there to serve the garage -and not the counter- you can argue that GFI is not required. Wonderful- you've protected the unnecessary, never used outlets, and ignored the ones that get used.
Another issue is the matter of load calculations. There is no limit to the number of receptacles on a RESIDENTIAL circuit. Yet, the appliance garage is the one place that is sure to use a lot of watts. I expect that, in most cases, these receptacles are simply added to the small appliance circuits. While that may have the side-effect of getting them GFI protection, it also increases the chances of there being an overloading issue.
I think we've crossed the line here between "minimum for safety" and into "design" issues.