It helps in a couple of ways...
First, it is NEVER as cold as the outside. Outside could be 20 and garage would be 30. Still below freezing, but not as brutal. But the big advantage is no wind... no exposure. Cold doesn't kill trees that are in full winter dormancy... dryness does. Cold and wind = freeze-dried dead tree. So keeping it in a cold frame, or unheated greenhouse, or unheated garage, protects the trees from drying out. They hunker down, rest, and wait for spring. I would make snowballs, and put them on the soil of each of my trees in the garage. As long as the temps were below freezing, the snowball would stay. As soon as it got a little warm, the snowball would melt into the soil and let me know it was time for another snowball