Concept
The two flagship Asian single-family-office regimes: Hong Kong's FIHV (Family-owned Investment Holding Vehicle) concession and Singapore's Section 13O exemption. Both let a family-run investment vehicle pay no or near-no tax on qualifying investment income; both demand real local presence. The difference is in the thresholds, the substance math and the licensing path — and both regimes' key figures are verified as of 2026-07-20.
Entry Thresholds
- FIHV — aggregate NAV of Schedule 16C assets ≥ HK$240 million across a 2-year lookback (verified).
- 13O — S$20 million AUM at the time of application, with no build-up grace (conditions of 5 July 2023; the older S$10m + 2-year ramp is superseded — verified).
FIHV's bar is higher in absolute money (≈US$30m vs ≈US$15m) but sits on assets across the family group; 13O's is per fund structure.
Substance Demands
- FIHV — ≥2 qualified full-time employees in Hong Kong and ≥HK$2 million annual local operating expenditure; the vehicle must be centrally managed and controlled in Hong Kong (verified).
- 13O — ≥2 investment professionals (at least 1 non-family member), each on a fixed monthly salary above S$3,500 and spending more than half their time on the fund; annual local business spending S$200K / S$500K / S$1m by AUM tier; capital deployment of the lower of S$10m or 10% of AUM into specified local investments (all verified, MAS).
Singapore's test is more granular (headcount quality + spending + deployment); Hong Kong's is simpler but insists on central management in Hong Kong — a harder governance fact to fake.
Licensing and Process
Neither regime asks a pure single family office to hold a fund-management licence: Hong Kong's FIHV is a tax concession on the vehicle, not a licence; Singapore's 13O SFO typically relies on MAS's licensing exemption for single-family management, with the exemption application itself as the process. Timelines and documentary loads differ — verify current process parameters with the regulators (IRD / MAS).
Which Regime for Whom
- China-facing asset base, >US$30m, comfort with HK governance — FIHV; the Hong Kong tax profile behind it is light.
- ASEAN banking centre, operating family team in Singapore, fund-ecosystem depth (VCC) — 13O; pairs with Singapore residence for the principals.
- Both regimes coexist with the relocation question — see Singapore Tax Residency and Hong Kong Tax Residence for the personal layer.
Q/A
Which regime has a lower asset threshold?
Singapore 13O in absolute money: S$20 million at application (≈US$15m) versus FIHV's HK$240 million aggregate NAV (≈US$30m). Both verified as of 2026-07-20.
Which demands more local substance?
Different kinds: 13O is more granular (2+ investment professionals with salary and time tests, tiered local spending, a local capital-deployment rule); FIHV is simpler in count (2 FTE + HK$2m spend) but requires central management and control in Hong Kong — the deeper governance commitment.
Do I need a licence for a single family office in either?
No fund licence for a pure single-family setup in either jurisdiction: FIHV is a tax concession, and 13O SFOs run under MAS's licensing exemption for single-family management (verify current guidance with IRD / MAS).
Reviewed: 2026-07-21 · Sources: data_core tax-hk-fihv-concession, license-sg-13o-aum-min, license-sg-13o-13u-annual-spending, license-sg-13o-13u-investment-professionals, license-sg-13o-13u-capital-deployment (all verified 2026-07-20: IRD, MAS).
Cite as: wiki.private.law — "Hong Kong FIHV vs Singapore 13O: The Two SFO Regimes Compared", https://wiki.private.law/en/hong-kong-fihv-vs-singapore-13o (reviewed 2026-07-21).