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Designated Investments and Specified Income: The Scope of Singapore's Fund Tax Exemptions

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Singapore's fund tax incentives — sections 13D, 13O and 13U — do not exempt a fund's income wholesale. They exempt specified income from designated investments, and these two lists draw the real perimeter of the concession: an asset outside the list produces taxable income and, since 2025, also drops out of the AUM test.

Where the list lives

The Income Tax Act 1947 contains no list of its own — both sit in subsidiary legislation. The base text is S 6/2010, regulations made under section 13D; S 8/2010 mirrors it for 13O and S 414/2010 for 13U. The operative version is the Fifth Schedule — Part A for designated investments, Part B for specified income — applying to income derived on or after 19 February 2022.

The regulations are the legal source; MAS reproduces both lists in Annex 3 of FDD Cir 05/2026. The current text of the Fifth Schedule was inserted by S 723/2025, published on 24 November 2025 with retroactive effect.

What Part A covers

Paragraphs (a) to (za) sweep in nearly the entire liquid investment universe: stocks and shares of any company, bonds, notes, commercial paper, certificates of deposit, REITs and ETFs, futures, deposits with financial institutions, foreign exchange, the main derivative classes, unit trusts, loans and credit facilities, structured products, partnership and LLC interests, Islamic financing arrangements, freight and emission derivatives, liquidation claims.

Almost every group carries a condition:

Asset groupCondition / carve-out
Stocks, bonds, securitiesexcept paper of unlisted companies trading in or holding Singapore immovable property
Immovable propertyoutside Singapore only
Loans and credit facilitiesexcept loans to unlisted SG-property companies or financing Singapore property purchases
Physical commoditiesonly incidental to commodity-derivatives trading, ≤15% of combined volume per basis period
Physical investment precious metalsaverage monthly position ≤5% of the portfolio in the Fifth Schedule text; MAS FDD Cir 05/2026 of 31 July 2026 removes the 5% cap from 1 August 2026
LLC membership interestsfrom 24 Nov 2025 — only if the LLC carries on no trade or business in Singapore

What stays outside

Cryptocurrencies and digital payment tokens appear nowhere in the Fifth Schedule, so the income they generate falls outside the exemption. Artwork, wine, cars and other collectibles are not on the list either. Singapore real estate, precious metals above the 5% cap and physical commodities beyond the incidental limit are equally out.

Specified income: everything but four exclusions

Since 19 February 2019 specified income has been defined as an exclusion list — in Part B of the Fourth Schedule until 18 February 2022 and in Part B of the Fifth Schedule since: any income or gains from designated investments qualify, minus four items — distributions by a REIT trustee, distributions by Singapore-resident trustees (except those themselves exempt under 13D/13F/13L/13U), and Singapore-sourced income paid out of partnership or LLC income already taxed in Singapore — a guard against double-dipping.

Why the list matters more since 2025

The list itself has not changed substantively since February 2022: S 723/2025 was surgical — the LLC condition, deletion of the "approved start-up fund manager" definition, technical fixes. What changed is the list's role. From 1 January 2025, AUM for 13O/13OA/13U is measured by the value of designated investments — net of designated investments recognised as liabilities, with no deduction for loans taken to finance them (MAS FDD Cir 10/2024; FAQ in FDD Cir 05/2026). For general funds under a licensed manager the S$5 million and S$50 million thresholds are entry conditions: MAS FDD Cir 05/2026 of 31 July 2026 removed the annual re-test retroactively from 1 January 2025, and a 13O or 13OA fund may reach S$5 million by the end of the third year of assessment of the award. For single family offices with awards applied for from 5 July 2023 the S$20 million (13O) and S$50 million (13U) in designated investments are required at application and at the end of each basis period; earlier family-office awards carry no annual minimum (FDD Cir 05/2026, Annexes 6B and 7B).

For mixed-strategy funds this creates an all-or-nothing effect: non-DI assets do not merely produce taxable income — they vanish from the AUM test, putting the whole award at risk rather than a slice of the portfolio. The exposure is sharpest on the family-office track, where the threshold is held every basis period; a general fund under a licensed manager passes the test once at entry.

Who should care

Anyone structuring a Singapore fund or family office around non-standard assets: private credit against Singapore projects, physical gold, crypto, real estate. A classic portfolio of listed securities, bonds, deposits and foreign funds passes the list without friction. Strategies involving digital assets or Singapore property require either moving those assets outside the fund's perimeter or accepting tax on that slice — with the 2025 AUM test factored in.

Q/A

What the list covers

Does the exemption cover crypto income?

No. Digital payment tokens and crypto-assets are absent from the Fifth Schedule, so the income is not specified income and is taxed normally. Since 2025 crypto also does not count towards the 13O/13U AUM test.

Can the fund hold Singapore real estate?

Not directly — only immovable property outside Singapore is a designated investment. The side doors are shut as well: unlisted SG-property company paper and property-linked loans are carved out. The share carve-out does not extend to property development companies.

Can the fund hold physical gold?

Under the Fifth Schedule text, only in small size: physical investment precious metals are designated investments while the position stays at or below 5% of the portfolio unless the Comptroller allows otherwise, a cap MAS FDD Cir 05/2026 of 31 July 2026 removes from 1 August 2026; other physical commodities qualify only incidentally to commodity-derivatives trading, up to 15% of combined volume per basis period. Above those caps the holding is not a designated investment: the income is taxable and, since 2025, the asset also drops out of the AUM test.

How the two lists work

Has the list changed recently?

Not substantively: the current edition applies to income derived on or after 19 February 2022. The November 2025 amendment (S 723/2025) added the LLC no-Singapore-business condition and technical fixes only. MAS FDD Cir 05/2026 of 31 July 2026 removed the 5% cap on physical investment precious metals with effect from 1 August 2026; the Fifth Schedule text still carries the cap until the regulations are amended.

Designated investments vs specified income — what is the difference?

Part A answers what the fund may hold; Part B — which income from it is exempt. Since 19 February 2019 specified income is defined as everything except four exclusions.

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