For questions relating to the Revised Framework for Single Family Offices, please refer to the “FAQs on Licensing Exemption Framework for Single Family Offices” dated 12 June 2026.

Yes, please notify MAS on such additions or replacements of persons and entities related to the SFO and S13O/OA/U SFO fund, as this is material information that has changed compared to the point of the application. Please provide the following details of the change to MAS, by writing to FO_13OU@mas.gov.sg :

• Registered / Full name (as per passport for individuals), including in native characters if applicable
• UEN/ Business registration number (for corporates)
• Place of incorporation (for corporates)
• Date of incorporation (for corporates)/ Date of birth (for individuals)
• Citizenship (for individuals; please list all citizenships, and past citizenships, if more than one. Please also indicate if the individual is a Singapore Permanent Resident)
• Gender (for individuals)
• Relationship to beneficial owner
• Revised shareholding structure if applicable
• Role in SFO (for individuals)

Yes, provided the SFO fund is not:

• intended to facilitate the treasury operations of any operating business or corporate group; or
• an S13U fund owned, whether directly or indirectly, by a Singapore operating company or Singapore corporate group. 

Please notify MAS, by writing to (i) FO_13OU@mas.gov.sg  (for SFO funds), or (ii) 13O_FundRF@mas.gov.sg or 13U_FundET@mas.gov.sg (for non-SFO funds), on your intention to replace the fund manager.

Where an S13O/OA/U fund intends to change its fund manager from a non-SFO to an SFO, the fund will be required to submit a fresh application to MAS for an S13O/OA/U award applicable to SFO funds (“SFO application”). Concurrently, to facilitate the termination of its existing S13O/OA/U award under the scheme for non-SFO funds, the fund must submit the Annual Declaration for the relevant basis period up to the last day of the existing award (i.e. the day immediately preceding the submission of the SFO application). Should the SFO application be approved, the commencement date of the new award will be the date the application is submitted, to avoid any disruption in the tax incentive coverage period. 

The same approach applies where an existing S13O/OA/U fund changes its fund manager from an SFO to a non-SFO. 

Please note that the conditions (e.g. minimum annual spending condition) applicable to an S13O/OA/U fund managed by a non-SFO differ from those applicable to an S13O/OA/U fund managed by an SFO. 

The SFO fund cannot avail itself of the tax exemption for the basis period concerned when its AUM in DI falls below S$20 million (for an S13O/OA fund) or S$50 million (for an S13U fund) as at the end of the basis period. 

The SFO fund can, however, avail itself to the tax exemption in any subsequent basis period, if it has AUM in DI of at least S$20 million (for an S13O/OA fund) or S$50 million (for an S13U fund) as at the end of that basis period and satisfies all other relevant conditions of the scheme in that basis period. 

Yes, S13O/OA/U SFO funds may hold investments in operating businesses of the family, and such investments are not subject to any holding limits. For the purpose of assessing various conditions, the following apply:

• Investments (whether in the form of equity, debt or other financing arrangements) in operating businesses of the family will not count towards meeting the minimum AUM in DI condition. 
• However, such investments will count towards all other relevant conditions (e.g. the minimum annual business spending and the Capital Deployment Requirement), provided that the investments qualify as DIs. 

For the purpose of assessing whether the investment into an LP fund counts towards Option 2 of the CDR, the LP fund must be a DI175 as well as be distributed by licensed financial institutions in Singapore, excluding equities listed outside of Approved Exchanges.

An operating company with substantive presence in Singapore generally has the following characteristics: 

• Is a business entity that is registered in Singapore; 
• Has at least 25% local shareholding interest; 
• Has a minimum of 3 employees in Singapore; and 
• Has an operating premise in Singapore. 

Entities that are involved in the business of trading or holding of Singapore immovable properties (other than one that is in the business of property development) do not qualify as investments under Option 3 of the CDR. 

For cases such as (b) and (c), the SFO fund must be able to demonstrate in its records that the definitions above are fulfilled for the underlying non-listed Singapore-incorporated operating company.

An indirect holding in a non-listed Singapore-incorporated operating company through a holding company will be considered as fulfilling Option 3 of the CDR, provided the following conditions are met: 

• The intermediate entities in the ownership chain are purely investment holding structures or special purpose vehicles (SPVs) with no independent business operations of their own; and 
• The underlying operating company is a non-listed Singapore-incorporated company with substantive business operations and a substantive presence in Singapore. 

Qualifying IPs are expected to be employed primarily as a portfolio manager, research analyst or trader in the conduct of investment management in an SFO. Examples of a qualifying IP’s responsibilities include: 

• Developing and implementing investment strategies, including building and managing investment portfolios; 
• Performing investment research and market analysis with recommendations to buy or sell a specific financial product or asset class; and 
• Trading of financial instruments, which could include liquidity management and deal structuring. 

Roles primarily relating to operations, administration, or finance / accounting are not considered to be qualifying IP roles. Examples of non-qualifying IP roles include: 

• Financial planning and analysis, budgeting, or capital account management;
• Cashflow monitoring; 
• Legal documentation and fund wiring; 
• Tax planning support; and 
• Passing on or keying in orders (i.e., trade settlement or confirmation). 

Qualifying IPs should possess either – 

• Relevant experiences, which include: 
  • Investment experience (including personal investment), or 
  • Professional experience in a formal employment capacity, in the conduct of portfolio management, research analysis, trading or undertaking in mergers or acquisitions, or 
• Relevant academic qualifications, which include: 
  • A degree/ master’s qualification in Accountancy, Finance, Economics, Business Administration/ Management, Financial Engineering, or with a specialisation in any of these fields, or a relevant diploma from a Singapore institution in any of the preceding areas, or 
  • Relevant professional certification (e.g., CMFAS or CFA).