Most Singapore SFOs use a two-vehicle structure that separates asset ownership from asset management.
The requirements below apply to families seeking the 13O or 13U tax incentive. That incentive is the main commercial reason most families formalise an SFO. The figures reflect the conditions for new SFO awards approved on or after 1 August 2026. They apply regardless of the founder’s nationality, so there is no separate “foreigner” track.
The families who move through this smoothly treat the project as the launch of a small operating business, with real headcount, spending and governance. MAS assesses it in exactly that light.
The AUM threshold drives most of the decision. Below S50million,13O is effectively the only option. Between S50 million and roughly S$70 million, 13O often remains attractive because the team is smaller and the Singapore residency requirement for the fund vehicle suits most families. Above that range, the offshore flexibility and institutional standing of 13U become more valuable. This matters most for families that want an offshore fund vehicle or are bringing assets over from existing offshore structures.
Both schemes deliver the same core outcome: specified income from designated investments is exempt from Singapore tax. The right choice is the one the structure can comfortably sustain in headcount and spending from day one. Qualifying funds also benefit from GST remission and withholding tax exemption, which adds to the overall efficiency of the structure.
Immigration planning works best alongside the setup. The main routes:
Children’s schooling, the spouse’s pass type, and longer-term residency plans all shape how SFO employment contracts are drafted. Bring the immigration adviser in before the entities are incorporated.
A single family office serves one family, so its strategy, governance and reporting are built entirely around that family’s goals. A multi-family office serves several families and balances their needs within one platform.
Existing SFOs have until 15 June 2027 to align with the class exemption and file a notice of continuation with MAS. SFO funds with earlier 13O or 13U awards also move to an updated set of conditions from the Year of Assessment whose basis period ends on or after 1 August 2026. A structure review now keeps both the licensing exemption and the tax incentive on track.
There is no statutory minimum to incorporate an SFO. The 13O tax incentive requires S20 million in designated investments and the 13U incentive requires S50 million. Both are tested at the point of application and at the end of each financial year. In practice, a dedicated SFO becomes cost-efficient at around S$50 million and above once headcount and spending are factored in.
13O is the onshore scheme, requiring S20 million AUM, two investment professionals and a Singapore- .13U is the enhanced tier, requiring S50 million AUM and three investment professionals, and it permits offshore fund vehicles. Both exempt specified income from designated investments from Singapore tax.
No CMS licence is needed. From 15 June 2026, a qualifying SFO operates under a dedicated class exemption under the SFA. Its conditions include meeting the banking requirements, notifying MAS within 14 days of commencing business, and filing an annual return within four months after each financial year-end. The 13O or 13U tax incentive is a separate MAS approval.
A VCC must appoint a permissible fund manager, such as a suitably licensed fund manager or a qualifying exempt financial institution. The SFO’s licensing exemption does not by itself qualify it to manage a VCC, so the manager appointment is planned when the structure is designed.
Listed equities, funds focused on Singapore-listed equities, blended finance instruments and non-listed Singapore operating companies count at twice their value. The CDR is first tested at the end of the basis period for the first full YA after the award starts, then at each basis-period end.
Two for 13O and three for 13U, including at least one non-family member. A 13O applicant may apply with one qualifying IP and a 13U applicant with two. The full requirement must be met by the end of the basis period of the first Year of Assessment. All IPs must be Singapore tax residents engaged substantially in investment management.
Incorporation takes one to two weeks. The full process typically spans six to twelve months, because the private banking account must be open before the tax incentive application is filed, and MAS review follows. Bank onboarding is often the longest workstream, so it is best started early.
The Global Investor Programme family office option offers a direct route for principals with at least S200 million in net investible assets and an SFO managing atleast S200 million. Principals working in Singapore on an Employment Pass may also apply for PR. ICA assesses each application on a range of factors, with no fixed minimum period.
No. Direct holdings of Singapore property, residential or commercial, are excluded from designated investments. Investments in the family’s own operating businesses also do not count towards the minimum AUM, though the fund may still hold them. Equities, bonds, funds, private equity and other designated investment classes qualify.
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