# Hong Kong FIHV vs Singapore 13O: The Two SFO Regimes Compared

> Hong Kong FIHV vs Singapore 13O for a single family office: 0% concession at HK$240m NAV vs 13O exemption at S$20m AUM day-one, substance tests (2 FTE + HK$2m vs IP + spending tiers + CDR), licensing exemptions.

Author: Мария Плотникова — юрист, Family Office (https://wiki.private.law/authors/plotnikova)
Last modified: 2026-07-21T18:10:00.000Z
Canonical: https://wiki.private.law/en/hong-kong-fihv-vs-singapore-13o
Topics: structures
Jurisdictions: hong-kong, singapore
Semantic tags: substance

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## 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.

> 💡 **Short answer.** Hong Kong's FIHV wins on tax rate and asset threshold; Singapore's 13O wins on ecosystem and predictability of process. The numbers: FIHV gives **0% profits tax** on qualifying transactions for a family-owned vehicle with at least **HK$240 million** (≈US$30m) in aggregate NAV (Schedule 16C assets, 2-year lookback), requiring ≥2 qualified full-time employees and ≥HK$2 million of local operating expenditure (verified, IRD). 13O exempts specified income of a Singapore fund managed by a SFO with **S$20 million AUM at application, day one** (conditions effective 5 July 2023), annual business spending of **S$200K / S$500K / S$1m** by AUM tier (<S$50m / S$50–100m / ≥S$100m), at least 2 investment professionals (one non-family), and a capital-deployment rule of the lower of S$10m or 10% of AUM into local investments (verified, MAS). Neither needs a fund licence for a pure single-family setup; both need substance that survives reading. Choose Hong Kong when the asset base is large and China-facing, Singapore when the operating team and banking centre sit in ASEAN — the wider frame is at [Family Office](https://wiki.private.law/en/family-office).

## 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](https://wiki.private.law/en/hong-kong-tax-residence) behind it is light.
- **ASEAN banking centre, operating family team in Singapore, fund-ecosystem depth (VCC)** — 13O; pairs with [Singapore residence](https://wiki.private.law/en/singapore-residence-permit) for the principals.
- Both regimes coexist with the relocation question — see [Singapore Tax Residency](/en/singapore-hub) and [Hong Kong Tax Residence](https://wiki.private.law/en/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](http://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](https://wiki.private.law/en/hong-kong-fihv-vs-singapore-13o) (reviewed 2026-07-21).

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## Sources

- [IRD — Inland Revenue Department](https://www.ird.gov.hk/)
- [MAS — Monetary Authority of Singapore](https://www.mas.gov.sg/)

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## FAQ

### 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).

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## Factual claims

- The two flagship Asian single-family-office regimes: Hong Kong's FIHV (Family-owned Investment Holding Vehicle) concession and Singapore's Section 13O exemption.
- 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.