Overview
A Singapore single family office (SFO) is usually a private limited company that manages the wealth of one family and is paid for that service by fund vehicles the family owns. Fund management is a regulated activity under the Securities and Futures Act 2001, but MAS has long treated genuine SFOs as exempt. From 15 June 2026 that treatment is codified as a class exemption: the SFO must be incorporated in Singapore, manage money only for family members (defined across five generations from a common ancestor, including spouses and in-laws), family-funded charities and a small circle of key employees, be funded only by the family and those employees (who may hold a non-controlling stake of up to 10%), and keep a bank account with an MAS-licensed bank. A new SFO files a notice of commencement within 14 days of starting business; existing SFOs have until 15 June 2027 to file a notice of continuation. An annual return reporting AUM and the bank used is due within four months of each financial year end. An office that serves more than one unrelated family is a multi-family office (MFO) and needs a Capital Markets Services licence for fund management, with the capital, compliance and fit-and-proper obligations that follow.
Licensing is separate from tax. Most families with substantial portfolios also apply to MAS for a fund tax incentive under section 13O (a Singapore-incorporated, Singapore-resident fund company, extended to Singapore limited partnerships by section 13OA from 2025) or section 13U (an enhanced-tier fund of any legal form, including a Variable Capital Company or an offshore vehicle). Approved funds are exempt on specified income from designated investments for the life of the award, while the SFO management company itself is taxed at the normal corporate rate on its fees. The schemes, with the related withholding tax and GST remission concessions, have been extended to 31 December 2029.
The incentives carry measurable conditions, and MAS circular FDD Cir 05/2026 of 31 July 2026 refined them for SFO funds from 1 August 2026. The AUM floor is S$20 million for 13O/13OA and S$50 million for 13U, measured in designated investments at application and at each financial year end. A 13O fund needs at least two qualifying investment professionals and a 13U fund three, with at least one who is not a family member; under the new rules one fewer may be in place at application, provided the full team is hired by the end of the first financial year. Local business spending is tiered: S$200,000 below S$250 million; S$500,000 (at least S$300,000 local) from S$250 million to S$2 billion; and S$1 million (at least S$500,000 local) from S$2 billion. Above the first tier, eligible donations to Singapore charities and grants to blended finance instruments may count at twice their value. The capital deployment requirement remains the lower of 10% of AUM or S$10 million, now invested across three categories with a 2x multiplier for specified Singapore-linked investments.
Singapore suits families that want an Asian base with predictable rules, strong banking and an English-law-based trust system. The trade-offs are real substance, a minimum cost base, careful screening (applications have required a screening report from an approved provider since October 2024) and an inability to market the exemption as regulation: exempt SFOs may not describe themselves as licensed or supervised by MAS. Many families pair Singapore with Hong Kong for Greater China investment, or with a European or Middle Eastern office for other branches of the family, and use a Singapore trust or private trust company for succession.
Key benefits
- Codified licensing exemption for genuine SFOs, with a simple notification rather than a licence application
- Exemption of specified income from designated investments for approved 13O, 13OA and 13U funds, available to 31 December 2029
- Choice of fund vehicle: Singapore company, limited partnership, Variable Capital Company or offshore fund
- Mature trust law, licensed trust companies and the option of a private trust company for family control
- Philanthropy Tax Incentive Scheme allowing qualifying donors in 13O/13U structures a 100% deduction for overseas donations through qualifying local intermediaries, capped at 40% of statutory income
- A route to permanent residence for principals through the Global Investor Programme family office option
- Access to a large private banking and wealth management ecosystem; MAS reported more than 2,000 SFOs with tax incentives at end-2025
Requirements
- Licensing exemption: Singapore-incorporated SFO serving only family members, family-funded charities and key employees (whose assets may not exceed 10% of AUM), funded exclusively by the family and key employees
- Bank account with an MAS-licensed bank for the SFO and its fund vehicles; foreign fund vehicles may use a bank in a jurisdiction applying FATF-consistent AML/CFT standards
- Notice of commencement to MAS within 14 days of starting business (existing SFOs: notice of continuation by 15 June 2027), a designated Singapore-resident point of contact employed by the SFO, and an annual return within four months of financial year end
- 13O/13OA: at least S$20m in designated investments at application and each financial year end; 13U: at least S$50m
- Qualifying investment professionals (portfolio managers, research analysts or traders) employed by the SFO: at least two for 13O/13OA and three for 13U, including one non-family member
- Tiered annual local business spending from S$200,000, rising to S$500,000 and S$1m at the S$250m and S$2bn AUM breakpoints
- Capital deployment of the lower of 10% of AUM or S$10m into listed investments on MAS-approved exchanges, investments distributed by MAS-licensed institutions, or non-listed Singapore operating companies with substantive local presence
- Private banking account with an MAS-licensed institution for the incentivised fund, maintained throughout each basis period
- AML/CFT screening of beneficial owners and source of wealth, including a screening report from an approved provider with the incentive application
- Ongoing filings: register of registrable controllers, CRS and FATCA reporting by in-scope entities, statutory audit where required, and written notice to MAS of material changes to owners, investment professionals or structure
Structure designs
SFO company with a 13O Singapore fund company
S$20m in designated investments
The most common entry structure: a Singapore management company holds the team and an investment management agreement with a Singapore-resident fund company. Suits families establishing their first office with a concentrated portfolio and a lean team.
SFO with a 13U fund (VCC, LP or offshore)
S$50m in designated investments
Enhanced-tier incentive for larger portfolios, with flexibility over the fund's legal form and residence. A VCC allows sub-funds for different branches or strategies; note that a VCC must be managed by a permissible fund manager, which shapes how the SFO is positioned.
Trust or private trust company over the structure
A Singapore trust holding the fund vehicles, with a licensed trust company or a family-controlled private trust company as trustee. Separates ownership from management and supports succession over generations; private trust companies rely on an exemption and must work with a licensed trust company for AML/CFT checks.
Global Investor Programme family office option
S$200m AUM; S$50m deployed
For principals seeking Singapore permanent residence: an SFO with at least S$200m in AUM, of which S$50m is transferred to Singapore and invested in equities on approved Singapore exchanges and maintained for the life of the re-entry permit. Administered by the Economic Development Board, with renewal linked to hiring family office professionals or residence.
Licensed multi-family office
Where the office will serve unrelated families or third-party capital, a Capital Markets Services licence for fund management is required, with base capital, compliance, risk management and audit obligations. Suits families intending to commercialise their platform.
Step-by-step process
- 1
Feasibility and structure design
Map the family, assets, residences and tax exposures in each country; choose between 13O and 13U, the fund's legal form and any trust layer; confirm that the office will fall within the SFO exemption.
- 2
Incorporation and banking
Incorporate the management company and fund vehicle with ACRA, appoint directors and a company secretary, and open accounts with an MAS-licensed bank, which will run its own source-of-wealth review.
- 3
Notify MAS of the SFO exemption
File the notice of commencement within 14 days of starting business, appoint a Singapore-resident point of contact and set up the annual return calendar.
- 4
Hire the investment team
Recruit qualifying investment professionals, including the non-family member, and apply for Employment Passes where needed; from 2025 the minimum qualifying salary for financial services is S$6,200 a month, rising with age and increasing from 1 January 2027.
- 5
Apply for the 13O or 13U incentive
Submit the application to MAS with the business plan, structure chart, investment management agreement and screening report; MAS issues an award letter setting out the conditions and commencement date.
- 6
Deploy capital and operate
Meet the capital deployment requirement by the end of the first full financial year, track local business spending, keep annual MAS and IRAS filings current, and review the structure as the family and rules evolve.
Typical documents
- Certified passports and proof of address for principals, directors and beneficial owners
- Family tree and group structure chart showing ownership of each entity
- Source-of-wealth and source-of-funds narrative with supporting evidence
- Screening report from an MAS-approved provider for the incentive application
- Constitution of the SFO and fund vehicle, and trust deed or private trust company documents where used
- Investment management agreement between the SFO and the fund vehicle
- Three-year business plan with projected AUM, hiring and local spending
- CVs and employment contracts of investment professionals
- Bank statements or custodian reports evidencing AUM in designated investments
- Board resolutions, registers of members, directors and registrable controllers
How Legal Wealth helps

Legal Wealth designs the Singapore structure around the family rather than around a template: we map residences and tax exposures, test the arrangement against the MAS exemption conditions and the 13O or 13U criteria, coordinate incorporation, banking and trust arrangements with licensed providers, and prepare the source-of-wealth file with the discretion it requires. After set-up we keep the compliance calendar, from the MAS annual return to capital deployment and spending tests, and help the family put governance in place through a family constitution and an investment committee. Contact info@legalwealthglobal.com.
Enquire with Legal WealthFrequently asked questions
Does a Singapore single family office need a licence from MAS?
Not if it meets the class exemption that took effect on 15 June 2026: it must be Singapore-incorporated, serve only the family, family-funded charities and key employees, be funded by them, and bank with an MAS-licensed bank. It must notify MAS within 14 days of commencing business and file an annual return. Offices serving unrelated families need a fund management licence.
What is the difference between 13O and 13U?
13O applies to a Singapore-incorporated, tax-resident fund company (13OA extends it to Singapore limited partnerships) and requires S$20m in designated investments and two investment professionals. 13U applies to funds of any legal form, including VCCs and offshore vehicles, and requires S$50m and three professionals. Both require one non-family professional, tiered local spending and capital deployment.
What changed on 1 August 2026?
Under MAS circular FDD Cir 05/2026, AUM is tested at application and each financial year end, investment professionals can be phased in during the first year, local business spending breakpoints moved to S$250m and S$2bn, and the capital deployment options were consolidated into three categories with a single 2x multiplier for specified investments.
Can family members work as the investment professionals?
Yes, but at least one qualifying investment professional must be a non-family member. Investment professionals must perform portfolio management, research or trading roles and be Singapore tax resident.
Does setting up a family office give the family residence in Singapore?
Not automatically. Staff, including family members employed by the office, can apply for Employment Passes if they meet salary and COMPASS criteria. Permanent residence for principals is available through the Global Investor Programme family office option, which requires an SFO with at least S$200m in AUM and S$50m invested in Singapore-listed equities.
How does Singapore combine with Hong Kong?
Families with Greater China interests often hold Asian investments through a Singapore incentivised fund while running a Hong Kong office for mainland and Hong Kong market access under the FIHV regime, or vice versa. Each office must meet its own local substance, staff and spending tests, so the split should follow where decisions are genuinely made.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
Sources
- MAS: Written reply to Parliamentary Question on family offices (2025)
- MAS: Philanthropy Tax Incentive Scheme for Family Offices
- EDB: Global Investor Programme factsheet (21 February 2025)
- MOM: Employment Pass eligibility
- Rajah & Tann Asia: Revised licensing exemption framework for SFOs commences 15 June 2026
- RSM Singapore: MAS updates tax incentive schemes for SFO funds (FDD Cir 05/2026)





