Schemes and Initiatives
Published Date: 05 July 2023

Fund Tax Incentive Schemes for Family Offices

The key objective of the Schemes is to support the growth of the asset and wealth management industry in Singapore by providing a conducive tax environment for Singapore-based fund management companies, including FOs to grow their Assets Under Management (“AUM”) in Singapore.

  • The changes below will apply to all new 13OU applications who have sent in preliminary submissions to MAS from 5 July 2023 10:00 AM SGT (inclusive) onwards.
  • Existing S13O and S13U awarded funds, in particular those who applied and approved after 18 April 2022, can choose to fulfil the conditions under the Tiered Spending Framework and Capital Deployment Requirement with the new options introduced when submitting Annual Declarations due after 5 July 2023.

 

Criteria  S13O  S13U 
Assets Under Management
  • Minimum S$20 million in Designated Investments at the point of application and throughout the incentive period
  • Minimum S$50 million in Designated Investments at the point of application and throughout the incentive period 
Investment Professionals 
  • Employ minimum 2 professionals, of whom at least 1 is not a family member of the beneficial owners at the point of application and throughout the incentive period 
  • Employ minimum 3 professionals, of whom at least 1 is not a family member of the beneficial owners at the point of application and throughout the incentive period 

Investment Professionals Requirements

for both S13O & S13U

  • Relevant formal work experience or academic qualifications to qualify as investment professionals
  • Qualified investment professionals must be employed as a portfolio manager, research analyst or trader who will earn more than S$3,500 per month and engage more than 50% of the time in the qualifying activity
  • Qualified investment professionals must be Singapore tax residents throughout the incentive period
Spending Requirement 
  • Tiered Spending Requirement*, with minimum S$200,000 in Local Business Spending
  • Tiered Spending Requirement*, with minimum S$200,000 in Local Business Spending
Capital Deployment Requirements# for both S13O & S13U
  • Investing lower of S$10 million or 10% of AUM in:
  1. Equities, REITS, Business Trusts, or ETFs listed on MAS-approved exchanges;
  2. Qualifying Debt Securities;
  3. Non-listed funds distributed by licensed financial institutions in Singapore;
  4. Investments into non-listed Singapore operating companies;
  5. Climate-related investments;
  6. Blended Finance[**] Structures aimed at supporting sustainable development, with substantial involvement of Financial Institutions in Singapore
  • 1.5x or 2x amount invested in eligible investments recognised for Capital Deployment Requirement computation#
Private Banking Account Requirements for both S13O & S13U
  •  The Fund must have a private banking account with a MAS-licensed financial institution at the point of application and throughout the incentive period

Changes w.e.f. 5 July 2023

 

*Tiered Spending Requirement

Eligible Donations and Grants to Blended Finance Structures with substantial involvement of Financial Institutions in Singapore will be recognised as eligible spending, starting 5 July 2023

   AUM < S$50 million S$50 million ≤ AUM < S$100 million  AUM ≥ S$100 million 
Spending Requirement of the Fund in each Year of Assessment ≥ S$200,000  ≥ S$500,000  ≥ S$1 million 
Spending Requirement may be met by:  
  • Local business spending: Minimum S$200,000 
  • Local business spending: Minimum S$200,000
  • Eligible donations[***]
  • Grants[^] to Blended Finance[**] Structures with substantial involvement of Financial Institutions in Singapore (recognised as 2x spending)
  • Total spending: ≥ S$500,000
  • Local business spending: Minimum S$200,000
  • Eligible donations[***]
  • Grants[^] to Blended Finance[**] Structures with substantial involvement of Financial Institutions in Singapore (recognised as 2x spending)
    Total spending: ≥ S$1 million

Changes w.e.f. 5 July 2023

[^] Grants refer to contribution with no return of principal and income.
[**] Blended Finance refers to the use of catalytic capital from public or philanthropic sources to increase private sector investment in sustainable development.
[***] 
Eligible Donations refer to donations to Singapore Registered Charities, Exempt Charities, or IPCs; excluding Grantmakers under MCCY's Grantmaker Scheme.

Infographic Example for 13OU   

#Capital Deployment Requirement (CDR)

  • Climate-related investments and blended finance will be recognised as eligible investments, starting 5 July 2023
  • 2x recognition given to Singapore listed equities and deeply concessional capital in blended finance structures, starting 5 July 2023

Certain types of eligible investments will enjoy a multiplier: the amount invested in those categories will be scaled up by a multiplier when computing if the CDR is met.

2x multiplier 1.5x multiplier 1x multiplier 
  • Deeply concessional capitalDeeply concessional capital is capital that (i) has zero income earned on the investment; or (ii) bears first loss before any other equity (including other capital contributions that are already concessional with lower returns) and earns lower return than any other equity or in blended finance structuresThis includes blended finance structures that are substantially arranged, managed, executed or originated in Singapore, which is defined as:
    a. More than half of the entities involved in arranging, managing, executing or originating the blended finance structure must be entities licensed by MAS; or
    b. More than half of the gross revenue from arranging, managing, executing or originating the blended finance structure must be attributable to SG licensed entities; or
    c. More than half of the costs  incurred in arranging, managing, executing or originating the blended finance structure are for expenses paid to (and hence attributable to revenue earned by) entities in Singapore.
    with substantial involvement of financial institutions in Singapore
  • Equities listed on MAS-approved exchanges
  • ETFsAs long as the master fund is listed in Singapore on Approved Exchanges licensed by MAS. with primary mandatesBenchmarked against Singapore indices such as STI, SiMSCI, or invest ≥ 50% in Singapore-listed equities as attested by an MAS-licensed financial institution to the Fund Management Company. to invest in Singapore-listed equities on MAS-approved exchanges
  • Non-listed funds distributed by licensed financial institutions in Singapore with primary mandates to invest in Singapore-listed equities on MAS-approved exchanges
  • Concessional capitalConcessional capital refers to financing where the financier accepts a lower rate of return or higher risk than that which the borrower or issuer ordinarily has to offer to financiers seeking commercial risk-adjusted rate of return, i.e., concessional capital provider receiving lower return for same risk or same return for higher risk within the capital structure of an investment. Concessional capital must be provided to unrelated entities or third-party blended finance or concessional capital vehicles. Concessional capital can fall within one of the following:
    I . Lower return (but still >0):
    a. Equity with lower return than other common equity, preferred equity or debt
    b. Debt tranche with lower return than other tranches of similar credit terms
    OR
    II. Subordination in liquidation or payment:
    a. Aside from deeply concessional capital, second loss equity with same or lower return than other common equity or debt;
    b. Subordinated debt with same or lower return to senior debt or debt of similar credit terms
    OR
    III. Lower return and/or higher risk due to timing differences:
    a. Earlier injection: Other terms being equal, concessional debt is injected first before commercial debt
    b. Deferred repayment: Other terms being equal, repayment of concessional debt is partially or fully deferred; Other terms being equal, equity with partially or fully deferred payment of dividend or principal vis-à-vis other equity holders.
    in blended finance structures[2] with substantial involvement of financial institutions in Singapore
  • REITS, Business Trusts, or ETFs[3] (whose primary mandate is not to invest in Singapore-listed equities) listed on MAS-approved exchanges
  • Qualifying Debt Securities
  • Non-listed funds distributed by licensed financial institutions in Singapore (with no primary mandate to invest in Singapore-listed equities)
  • Investments into non-listed Singapore operating companies
  • Climate-related InvestmentsClimate-related investments are defined as investments which are in activities that are identified within the green or transition category under the Singapore-Asia Taxonomy or any other internationally recognised definitions/ taxonomies. Investments can be for overseas purposes.
  • Non-concessional capital invested in blended finance structures [2] with substantial involvement of financial institutions in Singapore

Illustration example of Capital Deployment Requirement (CDR)

 

Download Infographics (490.9 KB)

For further queries on Section 13O and 13U for family offices, please contact us via our online form and indicate “(ATTN: FDD/FO Team) Updated Section 13O/U conditions” in the Feedback Information title as the subject.