4 August 2020


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)(“单一家族办公室”)的基本法律要求和单一家族办公室提供的有关服务。

A. 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 structure¹ of an SFO is seen below:


B. 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 (Cap 289), read together with the Financial Advisers Act (Cap 110), 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. Furthermore, 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:


  • 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.


C. Tax Schemes and Incentives in Singapore

Singapore has several tax incentive schemes under the Income Tax Act (Cap 134) (“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 13CA of ITA);
  2. Onshore Fund Tax Exemption Scheme (Section13R of ITA); and
    在岸基金税收豁免计划 (《新加坡所得税法》第13R条);和
  3. Enhanced Tier Fund Tax Exemption Scheme (Section13X of ITA)

This segment focuses on the tax incentive schemes for onshore funds. The key features and requirements of the schemes are as follows:


Tax Incentive Schemes
Section 13R Schemes
Section 13X Schemes
Fund’s Residence(1)
Singapore tax resident
No restrictions
Assets under Management (AUM)
No minimum sum at the point of application
Must have a minimum of SGD50 million at point of application
Fund Expenditure
At least S$200,000 local business spending in a year
At least SGD200,000 local business spending in a year.
Fund Administrator
Shareholding / Investors
Pursuant to Section 13R 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

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

Sections 13R and 13X schemes also allow family members who join the family office as investment professionals to apply for an Employment Pass in Singapore
Note: one pass per s13R entity and three pass per s13X entity (subject to approval by relevant authorities).

13R和13X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家族成员申请新加坡的工作准证 EP (Employment Pass)
注:13R计划的单一家族办公室可以获得1个EP配额 ,13X计划的单一家族办公室可以获得3个EP配额 (须经有关当局批准) 。

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.

最后,在新加坡设立家族办公室可以享受超过100多个的避免双重征税的扩国协定(Double Taxation Agreements),这使某些类型收入的税收可以获得减免甚至做到完全免税。

Our Observations

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.


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

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


This alert is for general information only and is not a substitute for legal advice.



On 1 December 2022, KPMG and ZICO Law entered into an agreement under which a number of law firms and teams from the ZICO Law network have joined the KPMG network of firms.

The deal will see more than 275 lawyers join over 2,900 legal professionals in the KPMG global organization, creating a significant legal footprint across Asia. It will offer legal services and solutions, a globally connected legal services platform, and specialists who work with leading technology providers to modernize legal functions across organizations. The strategic combination increases the total number of legal professionals in the KPMG network to over 3,750 across 84 jurisdictions. You may read the press release here.

For more information and to see how we can assist you in your desired jurisdiction, please follow the links below: