FAQs on the Schemes for Single Family Offices

Find out what are the frequently asked questions on the schemes that are managed by Single Family Offices (SFOs).

General Questions

What is a family member?
  • Please refer to the “Consultation Paper on Proposed Framework for Single Family Offices dated 31 July 2023”. The paper defines ‘family’ as individuals who are lineal descendants of a common ancestor (living or deceased), and their current and former spouses, adopted children and current and former stepchildren.
  • Some examples are provided below.
  • Please also refer to MAS’ responses to the consultation feedback and the final Framework for Singapore Family Offices when they are published.
Example 1: Cousins are beneficial owners
  • Example 2 illustrating family members in FAQs on the schemes for family offices
  • Cousin 1 and Cousin 2 are considered as a family, as they are from a common ancestor.
Example 2: Half-siblings are beneficial owners
  • Example 3 illustrating family members in FAQs on the schemes for family offices
  • Sibling 1 and Sibling 2 are considered as family, as they are from a common ancestor.
Do changes in (a) beneficial owners of a 13O/13U fund managed by a Single Family Office (“SFO”) (or beneficiaries where the fund is structured as a Trust), or (b) shareholders, directors, key employees (C-suites) and investment professionals in the SFO, (c) new intermediate entities in the shareholding of a 13O/13U fund or SFO, need to be reported to MAS after the approval of the section 13O/13U tax incentive?

Yes, please notify MAS on such additions or replacements of persons and entities related to the FO and section 13O/13U fund (the “awardee”), as this is material information that has changed compared to the point of the application. Please provide the following details of the change to the Authority, by writing to the officer-in-charge (“OIC”) and covering officer, and to FO_13OU@mas.gov.sg :

  • Registered / Full name (as per passport for individuals), including Mandarin 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 FO (for individuals)
  • Relevant academic qualifications and professional work experience (for individuals; if acting as an investment professional in the SFO)
  • Curriculum vitae (for individuals; if acting as an investment professional in the SFO)
I have an existing approved 13O/13U fund. What should I do if I wish to change in the fund manager of the 13O/13U fund from a Licensed Fund Management Company (“FMC”) to an SFO?
  • Please notify MAS, by writing to the officer-in-charge (“OIC”) and covering officer, and to FO_13OU@mas.gov.sg , on your intention to appoint an SFO as the manager of the fund.
  • We would like to highlight that the conditions applied to a 13O/13U fund managed by a Licensed FMC differ from the conditions applied to a 13O/13U fund managed by an SFO. For example, certain economic conditions and the number of Qualified Investment Professionals differ.

Assets Under Management ("AUM")

What happens if a S13O awardee has an AUM of S$10 million at the point of application but is unable to meet the required AUM of S$20 million by the end of the two-year grace period as stipulated in the letter of award1?
  • Awardees may fulfill the AUM conditions by the end of the grace period based on either the net asset value of the fund or the value of the fund’s gross assets in designated investments.
  • If the awardee is unable to meet the incentive’s requirement by the end of the grace period, the award will be revoked from the end of the grace period.
What happens if a S13O awardee has AUM of S$20 million at the point of application but the AUM subsequently falls below S$20 million, the minimum amount to be maintained annually as stipulated in the letter of award2?

The awardee cannot avail itself of the tax exemption for the basis period concerned when the AUM falls below S$20 million. The awardee can, however, avail itself to the tax exemption in any subsequent period, if it satisfies the relevant conditions in that subsequent period.

1 Under the 18 April 2022 conditions

2 Under the 5 July 2023 conditions

 


Capital Deployment Requirement (“CDR”)

The fund must invest the lower of (i) 10% of its AUM or (ii) S$10 million in:

  • Option 1: Equities, REITs, Business Trusts or ETFs listed on exchanges approved by MAS pursuant to Section 9 of the Securities and Futures Act 2001 (“Approved Exchanges”)
  • Option 2: Qualifying Debt Securities
  • Option 3: Non-listed funds distributed by licensed/registered financial institutions in Singapore
  • Option 4: Investments into non-listed Singapore-incorporated operating companies with operating business(es) and with substantive presence in Singapore
  • Option 5: Climate-related investments
  • Option 6: Blended finance structures with substantial involvement of entities in Singapore

Regarding Option 3 of the CDR, what does “distributed by” mean?

This refers to the marketing or selling of the fund.

Regarding Option 3 of the CDR, will an investment into a fund distributed by a global fund management company count if the global fund management company has a related licensed financial institution in Singapore?
The investment can count towards Option 3 of the CDR if the awardee has documents, e.g., sales agreement, that shows that the licensed financial institution in Singapore has directly distributed (e.g., sold, marketed) the fund to the awardee.
Regarding Option 3 of the CDR, will an investment into a Limited Partnership (“LP”) fund qualify?
For the purpose of assessing whether the investment into a LP fund counts towards Option 3 of the CDR, the LP fund must be a Designated Investment3 as well as a non-listed fund distributed by licensed/registered financial institutions in Singapore.
Regarding Option 4 of the CDR, how do you define: (i) operating companies and (ii) substantive presence in Singapore?

(a) Does it count if the section 13O/13U fund invests into a foreign holding company that holds a non-listed Singapore-incorporated company with operating business(es) and with substantive presence in Singapore?

(b) Would an investment into a Singapore holding/joint venture company which owns a wholly-owned Singapore subsidiary count?

  • 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 4 of the CDR.
  • For cases such as (a) and (b), the awardee must be able to demonstrate in its records that the definitions above are fulfilled.
3 Designated Investments are as defined in the Income Tax (Exemption of Income of Prescribed Persons Arising from Funds Managed by Fund Manager in Singapore) Regulations 2010.

Qualifying Investment Professionals (“IPs”)

What are the expected job roles of Qualifying IPs for the purposes of the Schemes?
  • 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 that are not considered to be 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).
What is considered as relevant formal work experience or academic qualifications of Qualifying IPs for the purposes of the Schemes?

  • Relevant academic qualifications include:
    • A masters/degree/diploma in Accountancy, Finance, Economics, Business Administration/Management, financial engineering, or a masters/ degree/diploma with specialisation in the preceding areas or
    • Relevant professional certification (e.g., CMFAS or CFA).
  • Relevant work experience include:
    • Experience in the conduct of investment management (see question above) in a formal employment capacity or
    • Experience in deal structuring in mergers and acquisitions (if the awardee has a focus on private equities/venture capital/direct investments).

Others

Need more help? Write to usindicating “[ATTN: FDD/FO Team] Questions on Updated Section 13O/13U conditions” in the Feedback Information Title.