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. Data as of July 2026.
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 received from 19 February 2022.
IRAS has never issued a consolidated e-Tax Guide for the three schemes, so the regulations on SSO remain the only official source. The full current text of the Fifth Schedule is reproduced in S 723/2025, gazetted 24 November 2025.
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 group | Condition / carve-out |
|---|---|
| Stocks, bonds, securities | except paper of unlisted companies trading in or holding Singapore immovable property |
| Immovable property | outside Singapore only |
| Loans and credit facilities | except loans to unlisted SG-property companies or financing Singapore property purchases |
| Physical commodities | only incidental to commodity-derivatives trading, ≤15% of combined volume per basis period |
| Physical investment precious metals | average monthly position ≤5% of the portfolio |
| LLC membership interests | from 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. KPMG classifies crypto-assets, artwork and wine as non-DI; the same logic captures cars and other collectibles. 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 Part B has worked as an exclusion list: 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 — not NAV, with no deduction for loans — and must be maintained at the end of every financial year (MAS FDD Cir 10/2024; KPMG's breakdown).
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.
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.
FAQ
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.
Has the list changed recently?
Not substantively: the current edition applies to income received from 19 February 2022. The November 2025 amendment (S 723/2025) added the LLC no-Singapore-business condition and technical fixes only.
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 2019 specified income is defined as everything except four exclusions.