A foreign corporate investor may invest in Norwegian property directly or through a Norwegian limited liability company or Norwegian partnership owning the property.
From a Norwegian corporate tax perspective it is normally most tax efficient to invest in a SPV comprised by the tax exemption method (owning the property), as dividends and gains would then be tax exempt at the level of the Norwegian investor. Foreign corporate investors investing in a Norwegian entity covered by the tax exemption method could benefit from the exemption from withholding taxes on dividend distributions (provided that the investor company has sufficient substance and is not resident in a low tax jurisdiction outside the EEA).
Source : PWC