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Singapore Single Family Office (SFO) 13O & 13U Guide 2026

2026 guide to Singapore Single Family Offices, the 15 June 2026 MAS licensing exemption, Section 13O and 13U tax incentives, AUM, investment professionals and local substance.

Statutory Overview & Legal Framework

Singapore's Single Family Office (SFO) framework changed on 15 June 2026. Qualifying SFOs can now rely on a structure-agnostic class exemption from fund-management licensing, provided they satisfy the prescribed conditions, notify MAS of their operations and maintain an account with a MAS-licensed bank in Singapore. The revised framework is separate from Singapore's Section 13O and 13U fund tax incentives. For SFO-managed funds, the current 13O and 13U economic-substance rules should not be confused with older pre-2025 or non-SFO summaries. A qualifying SFO 13O structure has a S$20 million minimum fund size in designated investments, at least 2 investment professionals, local investment and tiered business-spending requirements. Section 13U has a S$50 million minimum fund size, at least 3 investment professionals and higher substance requirements. The exact tax incentive conditions, designated investments, local-business-spending calculations and approval terms should be checked against the current MAS requirements before implementation.

MAS Single Family Office Framework From 15 June 2026

effective Date: 15 June 2026

structure: The revised regime is structure-agnostic and provides a straight-through class exemption from fund-management licensing for qualifying SFOs.

qualifying Conditions:

The SFO must satisfy the applicable family and business conditions under the class exemption.

The SFO must notify MAS of its operations.

The SFO must maintain an account with a MAS-licensed bank in Singapore.

The SFO must submit the required annual return to MAS.

new Sfo Notification: An SFO commencing operations on or after 15 June 2026 must submit the Notice of Commencement of Business to MAS within 14 days of commencing operations in Singapore.

annual Return: Qualifying SFOs must file the prescribed annual return containing information including total assets under management and the name of the bank maintaining the required account.

transition: Existing SFOs operating before 15 June 2026 have a one-year transitional period and must comply with the revised framework by 15 June 2027.

not Automatic Licence: The class exemption is not a general exemption for every family-office activity. If the entity conducts activities outside the qualifying SFO framework, separate licensing or regulatory analysis may be required.

Section 13O Tax Incentive for SFO-Managed Funds

Section 13O provides tax exemption for specified income derived by an approved fund from designated investments, subject to MAS approval and the scheme's conditions.

minimum Fund Size: For the SFO-managed 13O route, the fund must maintain at least S$20 million of assets under management invested in designated investments, subject to the applicable measurement and timing rules.

investment Professionals

minimum: At least 2 investment professionals

non Family: The current SFO framework requires at least 1 investment professional to be a non-family member.

grace Period: Where the applicable rules allow the one-year grace period to appoint the additional qualifying professional, the specific approval and transition conditions must be followed.

local Investment

minimum: At least the lower of 10% of AUM or S$10 million

timing: The local-investment condition is subject to the scheme's timing and any applicable grace period.

examples:

Qualifying Singapore-listed equities

Qualifying Singapore debt securities

Qualifying funds distributed by Singapore-based licensed or regulated fund managers

Qualifying investments in Singapore-incorporated operating companies

Not every Singapore asset qualifies as a designated local investment. The exact instrument must satisfy the applicable MAS definition.

business Spending

Below S$50 million

S$200,000 per basis period

S$50 million to below S$100 million

S$500,000 per basis period

S$100 million or more

S$1,000,000 per basis period

point: The applicable spending requirement must be satisfied in the relevant basis period. Local-business-spending and total-business-spending concepts should not be treated as interchangeable.

fund Manager: The fund must be managed or advised directly by the relevant Singapore family-office/fund-management structure satisfying the applicable MAS conditions.

important: Older material may describe a S$5 million 13O threshold. That figure relates to the non-SFO fund framework introduced under the post-2024 changes and should not be substituted for the current SFO-managed 13O requirements.

Section 13U Enhanced-Tier Fund Tax Incentive

Section 13U provides an enhanced fund tax exemption for qualifying funds subject to MAS approval and the applicable economic-substance and investment conditions.

minimum Fund Size: At least S$50 million of assets under management invested in designated investments at application and as required at each financial year end.

investment Professionals

minimum: At least 3 investment professionals

non Family: At least 1 must be a non-family member under the applicable SFO-managed conditions.

Qualifying investment professionals generally include portfolio managers, research analysts and traders who meet the applicable remuneration and activity requirements.

local Investment

The fund must satisfy the applicable local-investment condition under the 13U framework.

examples:

Qualifying Singapore-listed investments

Qualifying debt securities

Qualifying Singapore-distributed funds

Qualifying investments in Singapore-incorporated operating companies

The precise 13U local-investment computation and eligible instruments must be checked against the current MAS scheme terms; it should not be reduced to an unsupported single formula.

business Spending

Below S$50 million

S$500,000 per basis period

S$50 million to below S$100 million

S$500,000 per basis period

S$100 million or more

S$1,000,000 per basis period

important: 13U has a higher substance burden than 13O. The precise interaction between total and local business spending should be checked against the fund's approval conditions.

fund Manager: The fund must be managed or advised by a qualifying Singapore fund manager satisfying the applicable licensing or exemption requirements.

duration: The 13U tax incentive has been extended through 31 December 2029, subject to the applicable legislation and conditions.

13O vs 13U

Minimum fund size for SFO-managed route

S$20 million

Investment professionals

At least 2

Non-family IP

At least 1 under current SFO conditions

Local / economic substance

Required

AUM monitoring

Application and ongoing annual conditions

selection: 13O is generally the lower-entry SFO fund incentive, while 13U is designed for larger funds able to sustain higher AUM and substance requirements. The commercially preferable structure depends on the family's investment strategy and the fund's projected size.

Typical SFO Structure

management Entity: A dedicated Singapore SFO management entity can provide investment management and family-office services. The exact ownership and control structure must satisfy both the SFO licensing exemption and the applicable tax incentive.

fund Vehicle: The fund may use an appropriate legal vehicle, including a Singapore company or VCC where suitable. A VCC is not universally mandatory for an SFO or 13O/13U structure.

separation: The management entity and investment fund are legally distinct concepts. The SFO should not be described as automatically being the same legal entity as the fund.

banking: The new MAS SFO framework requires the qualifying SFO to maintain the specified account with a MAS-licensed bank in Singapore.

custody: Custody, fund administration, accounting, tax and other services depend on the investment structure and are separate from the MAS SFO class-exemption conditions.

Typical SFO Setup Sequence

Define the Family and Investment Structure

Determine the family members, beneficial ownership, management entity, fund vehicle, investment strategy and intended family-office activities.

Establish the Singapore Entities

Incorporate the SFO management entity and, where appropriate, the fund vehicle. Choose the vehicle according to the actual investment and governance requirements.

Build the Banking and Operating Infrastructure

Establish the required MAS-licensed-bank relationship and arrange appropriate investment, custody, accounting, tax and administrative infrastructure.

Notify MAS Under the 2026 SFO Framework

For a new qualifying SFO, submit the commencement notification within 14 days after operations begin.

Determine 13O or 13U Eligibility

Test fund size, designated investments, investment professionals, local investments, business spending and Singapore management requirements before applying.

Apply for the Fund Tax Incentive

Submit the relevant 13O or 13U application and supporting documentation to MAS for approval.

Maintain Ongoing Substance

Monitor AUM, investment professionals, local investments, business spending, fund-management arrangements and other approval conditions throughout the incentive period.

File Ongoing Regulatory Returns

Submit the MAS SFO annual return and all other required tax, corporate and fund-related filings by the applicable deadlines.

Ongoing Compliance

requirements:

Maintain the conditions of the MAS SFO class exemption.

Keep the MAS-required bank account in Singapore.

File the SFO annual return within the applicable period.

Maintain the required fund AUM in designated investments.

Maintain the required number and profile of investment professionals.

Meet the applicable local-investment requirement.

Meet the applicable annual business-spending requirement.

Maintain qualifying Singapore fund-management arrangements.

Retain evidence supporting tax-incentive conditions and calculations.

Reassess the structure before major changes to ownership, family beneficiaries, investment strategy or management arrangements.

Frequently Asked Questions (FAQ)

MAS introduced a structure-agnostic class exemption from fund-management licensing for qualifying SFOs. New SFOs must notify MAS within 14 days of commencing operations, maintain the required Singapore bank relationship and submit the prescribed annual return. Existing SFOs have a transition period until 15 June 2027.

They are separate regimes. The SFO class exemption concerns whether a qualifying SFO can conduct its family-office activities without a fund-management licence, while Sections 13O and 13U provide tax exemptions for qualifying funds that satisfy their own approval and economic-substance conditions.

For the SFO-managed 13O route, the fund must meet a S$20 million minimum fund size in designated investments, together with the applicable investment-professional, local-investment, business-spending and Singapore management requirements. Older S$5 million references can relate to non-SFO fund conditions and should not automatically be applied to SFO structures.

Section 13U requires at least S$50 million of AUM invested in designated investments, together with the applicable investment-professional, Singapore fund-management, local-investment and business-spending conditions.

The current SFO-managed framework requires at least 2 investment professionals for 13O and at least 3 for 13U, with the applicable non-family-member condition. The investment professionals must satisfy the scheme's substantive role and remuneration requirements.

Yes. A VCC can be used as an appropriate fund vehicle, but it is not mandatory for every SFO structure. The correct vehicle depends on the family's investment strategy, governance, investor structure and applicable regulatory and tax requirements.

Legal Disclaimer: This page is general informational content, not legal, tax, regulatory, investment or wealth-management advice. Family-office structures and Section 13O/13U eligibility depend on the family, fund vehicle, designated investments, investment professionals, Singapore management, local investment, business spending and other approval conditions. Obtain current MAS and IRAS guidance before implementing or changing an SFO structure.

Verification Standard: Current MAS and IRAS materials checked in August 2026. No government endorsement, approval, accreditation or official verification of this website is claimed.

Primary Statutory References & Government Portals

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ACRA Compliance at a Glance

SFO frameworkMAS class exemption from 15 Jun 2026

13O SFO fund thresholdS$20M designated-investment AUM

13U fund thresholdS$50M designated-investment AUM

13O investment professionalsAt least 2

13U investment professionalsAt least 3

Existing SFO transitionUntil 15 Jun 2027

Documents Checklist

SFO management-company ACRA information
Fund-vehicle ACRA and constitutional documents where applicable
Family ownership and beneficial-ownership documentation
Investment management or advisory agreement
Evidence of Singapore banking relationship
13O or 13U tax-incentive application and supporting schedule
Evidence of designated investments and AUM
Investment-professional employment records
Local-investment evidence
Business-spending records and supporting invoices
MAS SFO notification and annual-return records
Financial statements and tax computations

Key Pitfalls to Avoid

✕ Treating the MAS SFO licensing exemption and 13O/13U as one scheme.

✓ The 2026 SFO licensing exemption and the fund tax incentives are separate regulatory and tax regimes.

✕ Using the old SFO licensing exemption structure after 15 June 2026.

✓ New SFOs from 15 June 2026 operate under the revised structure-agnostic class-exemption framework, subject to its conditions and notification requirements.

✕ Using S$5 million as the minimum AUM for every 13O family-office structure.

✓ The S$5 million figure relates to the current non-SFO fund framework. The SFO-managed 13O route has the separate S$20 million requirement.

✕ Saying a VCC is mandatory for every SFO.

✓ An SFO can use an appropriate fund vehicle; a VCC is one possible structure, not a universal statutory requirement.

✕ Treating local investment as simply buying any Singapore asset.

✓ Only qualifying investments within the applicable MAS framework count toward the local-investment condition.

✕ Using one flat spending threshold for all 13O and 13U funds.

✓ Business-spending requirements are tiered according to AUM and differ between 13O and 13U.

✕ Assuming that meeting the AUM threshold alone guarantees tax exemption.

✓ AUM is only one condition. Approval, Singapore management, investment professionals, local investment, business spending and other statutory requirements must also be satisfied.