Section 13O of the Income Tax Act is the workhorse exemption for Singapore single family offices: a Singapore fund company managed by the family's own SFO. The SFO framework has been fixed since 5 July 2023 and remains unchanged as of July 2026 — the tightening in MAS Circular FDD Cir 10/2024 touched non-SFO funds only.
The concept
The fund company's specified income from designated investments is exempt from tax; the vehicle is managed by the family's private SFO. The award is granted by MAS after a preliminary submission to the Financial Development Department and carries conditions for the whole incentive period. The 13D/13O/13U schemes run until 31 December 2029 (MAS). How 13O compares with 13U and offshore 13D — see the scheme overview.
Thresholds and the team
AUM: at least S$20 million in designated investments — at submission and throughout the incentive period. The grace period for building up AUM was abolished on 5 July 2023, so the threshold cannot be reached after filing. If AUM dips below S$20m, the exemption is unavailable for that basis period and resumes the next period once conditions are met again (MAS FAQ).
Investment professionals: minimum two, at least one from outside the family. An IP is a portfolio manager, research analyst or trader earning above S$3,500 a month, spending more than half their time on qualifying activity and remaining a Singapore tax resident throughout. Operations, administration and finance roles — budgeting, cashflow monitoring, document and tax support, order entry — do not count. Qualification is shown by a relevant degree, certification (CMFAS, CFA) or investment-management / M&A experience.
| Condition | 13O (SFO) | 13U (SFO) |
|---|---|---|
| AUM in designated investments | ≥ S$20m | ≥ S$50m |
| Investment professionals | ≥2, incl. ≥1 non-family | ≥3, incl. ≥1 non-family |
| Annual spending | tiered: S$200K–1m | tiered: S$200K–1m |
| Capital deployment | lower of 10% of AUM / S$10m | lower of 10% of AUM / S$10m |
Spending and capital deployment
The Tiered Spending Requirement tracks AUM: under S$50m → at least S$200K per year of assessment; S$50–100m → S$500K; S$100m and above → S$1m. Within any tier at least S$200K must be local business spending; above that, eligible donations to Singapore charities and blended-finance grants count, with grants recognised at 2x.
| AUM | Minimum annual spending |
|---|---|
| < S$50m | S$200K |
| S$50–100m | S$500K |
| ≥ S$100m | S$1m |
The Capital Deployment Requirement: invest the lower of 10% of AUM or S$10 million across six categories — equities/REITs/ETFs listed on MAS-approved exchanges, Qualifying Debt Securities, non-listed funds distributed by licensed FIs, stakes in non-listed Singapore operating companies, climate-related investments, blended finance structures. Multipliers soften the burden: 2x for SG-listed equities and deeply concessional capital, 1.5x for ETFs and funds mandated on SG-listed equities.
A separate condition is a private banking account with a MAS-licensed financial institution — at submission and throughout the period.
Process and timeline
The path: preliminary submission → review by the FO team at the Financial Development Department → award. Material changes — UBOs, IPs, structure — must be notified to MAS in writing. Since July 2025 MAS has targeted processing complete SFO applications within 3 months, against more than 12 months previously (Hubbis).
The checklist: fund company + SFO → private banking account → S$20m in designated investments before filing → two IPs (one non-family) → preliminary submission → after the award, annual MAS and IRAS filings.
Who it suits
Families with liquid capital from roughly S$20 million prepared for real substance: S$200K+ of local spending a year, a non-family hire, CDR investments into the Singapore market. It does not suit portfolios heavy in non-DI assets — crypto, art, Singapore property — which do not count towards the threshold. Capital well below S$20m is left with non-SFO tracks starting at S$5m, which mean a fund with an external manager rather than a family construct.
FAQ
How much AUM does 13O require for an SFO?
S$20 million in designated investments at submission — the grace period was abolished on 5 July 2023. 13U requires S$50 million.
What happens if AUM falls below the threshold?
The exemption is unavailable for the basis period in which the condition is breached and resumes the next period once conditions are met; the award is not automatically revoked (MAS FAQ).
Who counts as an investment professional?
Portfolio managers, research analysts, traders: salary above S$3,500 a month, over 50% of time on qualifying activity, Singapore tax residency throughout. Back-office and finance roles do not count.
How long does MAS take to approve?
Since July 2025 the stated target is up to 3 months for complete applications passing due diligence — down from over 12 months before.
Did the 2025 changes affect SFOs?
No. The S$5m minimum and the S$200/300/500K spending tiers from Circular FDD Cir 10/2024 apply to non-SFO funds, including the new 13OA for limited partnerships. SFOs stay on the 5 July 2023 framework.