13O 13U

Singapore Tax Incentive Schemes for Fund and Fund Managers

Singapore’s status as a prominent Asian hub for fund management can be attributed, in part, to its comprehensive tax incentive schemes. Many global fund houses have recognized Singapore as an ideal regional hub, choosing to establish their portfolio management, trading, and research operations within the country.

To solidify its position as a leading Asian fund management and domiciliation hub, the Monetary Authority of Singapore (MAS) is strategically leveraging its external fund management program to enhance asset management capabilities within Singapore. Concurrently, MAS collaborates closely with industry stakeholders to position Singapore as a prominent regional hub for fund domiciliation, an objective facilitated by the implementation of the Singapore Variable Capital Company (VCC) framework. Moreover, Singapore’s attractive tax framework and incentives for funds and fund managers serve as key catalysts in these endeavors.

It is important to note that funds managed by Singapore-based fund managers may be subject to tax in Singapore due to the investment management activities performed within the country. The income and gains derived by these funds could be deemed Singapore-sourced and thus subject to taxation, contingent upon the onshore or offshore classification of the fund and its taxable presence in Singapore. However, Singapore’s tax incentives aim to alleviate such tax obligations, provided that specific conditions are met.

Singapore’s conducive regulatory environment, extensive array of service providers, and favorable tax incentives have collectively contributed to the sustained growth and attractiveness of its fund management industry. By offering these enticing features, Singapore continues to establish itself as a premier destination for fund management within the Asian region.

Singapore Tax Exposures for Funds:

Funds managed by a fund manager in Singapore may be subject to tax in the country due to their investment activities. The income and gains generated by these funds may be considered Singapore-sourced and taxable, depending on whether the fund is based onshore or offshore. However, Singapore offers tax incentives that can eliminate these tax liabilities if certain conditions are met.

Tax Incentive Schemes in Singapore for Funds:

All fund management companies in Singapore must be licensed and registered with the Monetary Authority of Singapore (MAS). This requirement is necessary to qualify for the tax incentive schemes.

Under these schemes, certain income derived from funds managed in Singapore by a fund manager is exempt from taxation. The investments covered under these schemes include stocks, company shares, bonds, notes, commercial papers, treasury bills, certificates of deposit, derivatives, and more. However, immovable property in Singapore is not eligible for these incentives.


MAS Announces Stricter Criteria for Singapore’s 13O and 13U Fund Management Tax Incentive Schemes

Singapore’s Monetary Authority of Singapore (MAS) recently announced significant changes to the criteria for the Section 13O and 13U fund management tax incentive schemes. These changes are targeted at fund vehicles managed by family offices. The new criteria will take effect from 18th April 2022, and it is important for potential applicants to be aware of these changes and consider their options promptly.

Cases Covered by the New Criteria

The new stricter criteria will apply to cases where the first “preliminary submission” is made from 18th April 2022. However, cases that have already been granted the Section 13O or 13U awards by MAS or are in the process of application will generally not be affected. It’s worth noting that if a pending application has been stagnant with no communication with MAS for six months or more, MAS may require the application to be restarted under the new criteria.

Enhancements to the Award Criteria

For Section 13O Cases

  • The fund must now have a minimum fund size of S$10 million at the point of application and must commit to increasing its assets under management (AUM) to S$20 million within two years.
  • The family office must have a minimum of two investment professionals (IPs), with a grace period of one year to employ the second IP.
  • The absolute minimum total business spending annually remains at S$200,000, but this is subject to a new ‘tiered business spending framework’ pegged to AUM size.

For Section 13U Cases

  • The existing minimum fund size of S$50 million at the point of application remains unchanged.
  • The family office must have at least three IPs, with at least one IP being a non-family member. A grace period of one year may be given for the non-family member IP.
  • The absolute minimum local business spending annually is raised to S$500,000 (from S$200,000) in any basis period, and is also subject to a new ‘tiered business spending framework’ pegged to AUM size.

Common Requirements for both Sections 13O and 13U

Both Section 13O and 13U cases now have a new requirement for the fund to make local investments. This must constitute at least 10% of the fund’s AUM or S$10 million, whichever is lower, at any given time. Local investments include equities listed on Singapore-licensed exchanges, qualifying debt securities, funds distributed by Singapore-licensed/registered fund managers, and private equity investments into non-listed Singapore-incorporated companies with operations in Singapore.

If you’d like to read the full article and get more insights into the changes announced by MAS, you can find it here.

Disclaimer: This article is provided for informational purposes only and does not constitute legal advice. Professional legal advice should be sought before making any decisions or taking any actions based on the contents of this article.




Singapore Family Office

A family office is an organization created to manage the wealth and investments of a high net worth family or individual. It provides a range of services such as investment management, tax planning, philanthropy, and estate planning. Singapore is an attractive location to set up a family office due to its stable economy, favorable tax policies, and business-friendly environment.

The following is a step-by-step guide to setting up a family office in Singapore:

Step 1 : Define your objectives

Before setting up a family office, it is important to determine the objectives of the office. This includes identifying the family’s current and future financial needs, goals, and priorities. This will help in determining the type of services required from the family office.

Step 2: Choose the right structure

The next step is to choose the right structure for the family office. The most common structures are a single-family office, which is created for a single family, or a multi-family office, which serves multiple families. Other options include a private trust company or a corporate entity. Each structure has its own advantages and disadvantages, so it is important to choose the one that best fits the family’s objectives.

Step 3: Determine the regulatory requirements

Family offices in Singapore are regulated by the Monetary Authority of Singapore (MAS). The regulatory requirements will vary depending on the structure of the family office. For example, a single-family office may not be required to be licensed by the MAS, while a multi-family office will require a capital market services license. It is important to seek professional advice to ensure compliance with the regulatory requirements.

Step 4: Choose the right service providers

Once the structure has been determined and regulatory requirements have been met, the family office will require the services of various professionals such as lawyers, administrators, accountants, and investment managers. It is important to choose service providers who are experienced in working with family offices and have a good understanding of the family’s objectives.

Step 5: Implement the family office

Once all the steps above have been completed, the family office can be implemented. This include establishing policies and procedures, hiring staff, and setting up systems for investment management, accounting, and reporting. It is important to ensure that the family office is structured in a way that is flexible and can adapt to changing circumstances.

In conclusion, setting up a family office in Singapore can be a complex process, but with proper planning and guidance, it can be accomplished efficiently. It is important to define the family’s objectives, choose the right structure, determine the regulatory requirements, choose the right service providers, and implement the family office. Seeking professional advice is essential to ensure compliance with regulatory requirements and the successful implementation of the family office.