Setting up a Family Office in Singapore – Tightened criteria for Family Offices to qualify for tax incentives in Singapore 在新加坡设立单一家族办公室 – 收紧家族办公室享受新加坡税收优惠的标准

19 July 2022

Recognised for its political stability, sound financial regulations and pro-business policies, it is unsurprising that Singapore has established itself as one of the leading private banking and wealth management hubs in Asia. The Singapore government has further introduced various tax incentive schemes targeted towards funds managed by family offices, such as income tax exemptions on almost all investment gains. Consequently, Singapore has increasingly become the jurisdiction of choice for ultra-high net worth (“UHNW”) individuals and families to set up base to manage their assets and investments, specifically, by setting up a family office. This article gives a brief overview of setting up a single-family office (“SFO”) in Singapore and what SFOs have to offer.

新加坡因其稳定的政治环境,完善的金融法规和有利于商业运作的公共政策受到认可并成为亚洲领先的私人银行和财富管理中心之一。新加坡政府还针对家族办公室管理的基金推出了多项税收优惠计划,例如免征几乎所有投资收益的所得税等。有鉴于此,新加坡已逐渐成为超高净值人士和家庭设立资产管理和投资基地的首选法域,特别是采用在新加坡设立家族办公室的方式。本文概述了在新加坡设立单一家族办公室(Single Family Office) 的基本法律要求和单一家族办公室提供的有关服务。

What is a Single-Family Office?

An SFO typically refers to a legal entity that carries out the administration and management of assets and investments of UHNW individuals or families for the purposes of capital preservation, succession planning and managing investments. An illustration of a typical ownership structure[1] of an SFO is seen below:


To set up a Single Family Office (SFO) in Singapore, applicants must have a holding company and an investment vehicle that can be onshore or offshore.

SFO Regulatory Requirements in Singapore

Although fund management companies in Singapore are generally required to be licensed by the Monetary Authority of Singapore (“MAS”), the Securities and Futures Act 2001, read together with Financial Advisers Act 2001, provides exemptions for SFOs engaging in fund management and financial advisory activities from licensing requirements. For instance, under the statutory exemptions, an SFO may be exempted from licensing requirements if it was structured as either (a) a corporation which manages funds for its related corporations, or (b) a corporation that provides financial advisory services to its related corporations. In other words, SFOs performing such regulated activities will not need to be licensed by MAS. To clarify further, in the event that an SFO does not fall within the stipulated exemptions squarely, MAS has indicated its willingness to consider granting exemptions on a case by case basis. Typically, MAS will consider the following to be SFO arrangements:

虽然常规的新加坡基金管理公司均须事先获得新加坡金融管理局(“新加坡金管局”)(MAS)发出的基金管理牌照,但是《新加坡证券和期货法》(2001) 以及《新加坡财务顾问法》(2001) 在符合条件的情况下,针对为从事资金管理和财务咨询服务的单一家族办公室给予了对应的牌照的豁免。例如,根据法定的豁免规定,若单一家族办公室是(a)为其关联公司提供基金管理服务的公司,或(b)为其关联公司提供财务咨询服务的公司,则可获得牌照豁免。换句话说,对于此类管理自己家族财富的单一家族办公室无需再向新加坡金管局申请有关对应的基金管理牌照。需要进一步澄清的是,如果单一家族办公室不属于现有类别牌照豁免范围的公司,那么新加坡金管局则表示可按个别情况具体审核后给予牌照豁免。通常,新加坡金管局会将以下架构视作为典型的单一家族办公室:

  • Where there is no common holding company, but the assets managed by the SFO are directly held by natural persons of a single-family;
  • Where assets are held under a discretionary trust, the settlor of the trust and the beneficiaries are members of the same family;
  • Where a family trust is set up for charitable purposes, the charitable trust is funded exclusively by settlor(s) from a single-family; and
  • Where non-family members such as key employees of the SFO are shareholders in the SFO for the purpose of alignment of economic interest and risk-sharing, the initial assets and additional injection of funds are funded exclusively by a single-family.

MAS may take between two to four months to review an application for licensing exemption, depending on the complexity of the arrangement, the quality of the information submitted and the responsiveness of the applicants.


Tax Schemes and Incentives in Singapore

Singapore has several tax incentive schemes under the Income Tax Act 1947 (“ITA”) that are available for funds managed by family offices which allow for onshore and offshore family investment vehicles to be exempted from income tax on certain designated investments:


  1. Offshore Fund Tax Exemption Scheme (Section 13D (previously Section 13CA) of ITA);
  2. Onshore Fund Tax Exemption Scheme (Section 13O (previously Section 13R) of ITA); and
    在岸基金税收豁免计划 (《新加坡所得税法》第13O条(原为第13R条));和
  3. Enhanced Tier Fund Tax Exemption Scheme (Section 13U (previously Section 13X) of ITA)

This segment focuses on the tax incentive schemes for onshore funds. For applications submitted to the MAS from 18 April 2022 onwards, the key features and requirements of the schemes are as follows:

以下部份重点讨论在岸基金的税收优惠计划。对于从 2022 4 18 起提交给新加坡金管局的申请,该税收优惠计划的主要特点和要求如下:

Tax Incentive Schemes
Section 13O (previously Section 13R)
Section 13U (previously Section 13X)
Fund’s Residence*
Singapore tax resident


No restrictions


Assets under Management (AUM)
The fund entity must have a minimum of S$10 million at the point of application and commit to increasing AUM to S$20 million within a 2-year grace period


The fund entity must have a minimum of S$50 million at point of application


Investment Professionals
投资专业人士Note: Only individuals who are Singapore tax resident can be considered as investment professionals.:只有新加坡税收居民的个人才能被视为投资专业人士
(a)        The fund entity must be managed or advised directly throughout each basis period relating to any year of assessment by a family office in Singapore, where the family office employs at least two investment professionals (i.e., portfolio managers, research analysts and traders earning  more than S$3,500 per month and must be engaging substantially in the qualifying activity).

家办基金公司在任何评估相关年度需由家族办公室直接管理或提供建议。该家族办公室至少需要聘用2名投资专业人员(即投资组合经理、研究分析师和交易员,其收入需每月超过 3,500 新币,并且必须大量参与符合条件的活动)

(b)        In the event that the family office is unable to employ 2 investment professionals by the point of application, the fund entity would be given a 1 year grace period to employ the second investment professional.


(a)           The fund entity must be managed or advised directly throughout each basis period relating to any year of assessment by a family office in Singapore, where the family office employs at least three investment professionals (portfolio managers, research analysts and traders earning more than  S$3,500 per month and must be engaging substantially in the qualifying activity), with at least one being a non-family member.

家办基金公司在任何评估相关年度需由家族办公室直接管理或提供建议。该家族办公室至少需要聘用3名投资专业人员(即投资组合经理、研究分析师和交易员,其收入需每月超过 3,500 新币,并且必须大量参与符合条件的活动),其中一位投资专业人员必须是非家族成员。

(b)           In the event that the family office is unable to employ one non-family member as an investment professional by the point of application, the fund entity will be given a 1 year grace period to do so.


Business Expenditure
注:Expenses incurred should relate to the operating activities of the fund entity (as opposed to financing activities).产生的费用支出应与家办基金公司的运营活动有关(不包括融资活动)Typical expenditure includes, but are not limited to, remuneration, management fees, tax advisory fees, and operating costs.一般费用支出包括但不限于,薪酬、管理费、税务咨询费、及运营成本。
The fund entity will incur a total business spending of:


(a)           at least S$200,000 in a year if the Fund’s AUM is less than S$50 million;


(b)           At least S$500,000 in a year if the Fund’s AUM range is between S$50 million and S$100 million; or


(c)           At least S$1 million in a year if the Fund’s AUM is at least S$100 million


The fund entity will incur a total business spending of:


(a)           At least S$500,000 in a year if the Fund’s AUM is more than S$50 million but less than S$100 million; or


(b)           At least S$1 million in a year if the Fund’s AUM is more than S$100 million


Local Investment
The fund entity managed by the family office must invest at least 10% of its AUM or S$10 million, whichever is lower, in local investments, at any one point in time.


Such investments may include: (i) equities listed on Singapore-licensed exchanges, II) qualifying debt securities, (iii) funds distributed by Singapore-licensed/registered fund managers, (iv) private equity investments into non-listed Singapore-incorporated companies (e.g., start-ups) with operating business(es) in Singapore.


A grace period of one year will be granted if this requirement is not met at the time of application.


Fund Administrator




Shareholding / Investors
Pursuant to Section 13O of the ITA, non-qualifying investors (i.e. Singapore non-individuals investing above a certain prescribed percentage in the fund) will be required to pay a financial penalty to IRAS


No restrictions


Approval Requirement
MAS approval required for tax exemption scheme to apply (no change of investment mandate after approval)


MAS approval required for tax exemption scheme to apply (no change of investment mandate after approval)


Reporting Requirement
Annual statements to investors


Not required


Income Tax Filing
Must file annual tax returns to IRAS


Must file annual tax returns to IRAS


Annual Declaration to MAS




*   “Fund” in the table above refers to the investment vehicle(s) managed by an SFO.


Sections 13O and 13U schemes also allow qualified family members who join the family office as investment professionals apply for Employment Pass in Singapore.

13O和13U计划也允许以专业投资顾问身份加入家族办公室从事管理工作的合格家族成员申请新加坡的工作准证 EP (Employment Pass)。

All funds that qualify for any of the abovementioned tax incentive schemes as at 31 December 2024 may enjoy the tax exemption for the life of the fund (provided that the on-going operational conditions are met).


Lastly, Singapore has over 100 Avoidance of Double Taxation Agreements available to family offices which allows certain types of income to be taxed less or even exempted.



Singapore has long been an established financial and business hub and has a vibrant wealth management sector. As seen from the above, Singapore checks the boxes of what UHNW families consider to be essential when planning where to site their family offices. We believe that Singapore’s legal and tax landscape as well as its political stability would help further promote Singapore as an attractive destination for family offices serving wealthy families in the region.


If you have any questions or require any additional information, please feel free to reach out to Mr. Yap Lian Seng or Dr. Qiu Yang of Insights Law LLC.

IMPORTANT NOTICE: This memorandum is only intended as a guide and does not purport to be an exhaustive or conclusive discussion of the matters set out herein and should not be relied on as a substitute for definitive legal advice. Reference should always be made to the applicable statutes, the relevant subsidiary legislations and other applicable guidelines. This memorandum is not to be transmitted to any other person nor it is to be relied upon by any other person or for any other purpose or quoted or referred to in any public document or filed with any governmental or other authorities without our consent in writing. This memorandum is limited to the laws of Singapore. In issuing this memorandum, we do not assume any obligation to notify or inform you of any developments subsequent to its date that might render its contents untrue or inaccurate in whole or in part at such later time. If you would like to discuss the implications of these legal developments on your business or obtain advice, please do not hesitate to approach your usual contact at Insights Law LLC or you may direct the inquiry to our key contacts stated above.


[1] Ownership structure depends on the legal form of the holding/family office and various regulatory/operational considerations.