Investing in real estate through a holding structure allows you to protect your assets from the operational risks of other ventures. As a rule, it is not recommended to purchase property directly through a holding company—except in cases where the acquired real estate would carry minimal risk, such as buying solely for rental income purposes.

However, as a standard practice, it is advisable to use the holding structure to transfer capital to a subsidiary that will handle direct real estate investments. Such a subsidiary can be established in Norway to invest in the Norwegian market, but there is nothing preventing you from setting up a subsidiary in Poland (a limited liability company) and investing in the Polish real estate market there.

A Norwegian public limited company can establish a limited liability company in Poland, acting as its sole or principal shareholder. There are several legally defined variants in this regard:

1. The holding is 100% owner. This option is entirely feasible—however, the Norwegian company itself must have at least two shareholders (share proportions are irrelevant). Advantages: interest-free loans from Norway. Disadvantages: if the Norwegian company is liquidated, the holding’s shares must be sold to individuals in Poland.
2. The holding is 100% owner. This option is entirely feasible—however, the Norwegian company itself must have at least two shareholders (the share ratio is irrelevant). Advantages: interest-free loans from Norway. Disadvantages: if the Norwegian company is liquidated, the holding’s shares must be sold to individuals in Poland.
3. Two people set up a company in Poland—having two partners allows avoiding ZUS contributions. Loans from Norway are more problematic—they must be taxed, and withholding tax must be applied, etc.
   
   
   

Requirements:

In addition to the standard requirements that also apply to Norwegian companies—such as share capital, a registered office address, and a bank account—there is the obligation to register for a Polish tax identification number (NIP), statistical number (REGON), and, if the company will employ staff, with the Social Insurance Institution (ZUS).

Furthermore, it is advisable to obtain a “trusted profile” (profil zaufany), since without it neither the shareholders nor the management board can undertake any official actions.

Summary:

Connecting a business in Norway with one in Poland by establishing a limited liability company in Poland is a process that requires careful planning and an understanding of the regulations in both countries. A strategic approach and professional advice are essential for an effective and legally compliant expansion process.