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 thresholds have been fixed since 5 July 2023; the tightening in MAS Circular FDD Cir 10/2024 touched non-SFO funds only, and MAS Circular FDD Cir 05/2026 of 31 July 2026 rebuilt the SFO spending grid — for new awards and, from basis periods ending on or after 1 August 2026, for existing ones — gave new offices more time to hire investment professionals and simplified capital deployment to three asset options, leaving the S$20 million entry threshold as it was.
Short answer. Section 13O of Singapore's Income Tax Act exempts a Singapore fund company's specified income from designated investments when the fund is managed by the family's own single family office. For SFOs the thresholds are fixed since 5 July 2023: at least S$20 million in designated investments at submission (no grace period; 13U: S$50 million), at least two investment professionals including one non-family member, tiered annual spending from S$200K (breakpoints of S$250m and S$2bn under FDD Cir 05/2026 from basis periods ending on or after 1 August 2026, S$50m and S$100m before), and a capital-deployment requirement of the lower of 10% of AUM or S$10 million in qualifying investments (under FDD Cir 05/2026: listed on MAS-approved exchanges, distributed by MAS-licensed institutions in Singapore, or non-listed Singapore operating companies). The 13D/13O/13U schemes run to 31 December 2029.
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 its Financial Centre 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.
The SFO itself operates without a MAS fund-management licence: since 15 June 2026 it relies on a class exemption with mandatory notification — a Notice of Commencement of Business within 14 days of starting operations (offices already running before that date have until 15 June 2027).
Thresholds and the team
AUM: at least S$20 million in designated investments — at submission and at the end of every basis period; the fund's stakes in the family's own operating businesses do not count towards this minimum (FDD Cir 05/2026). 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. A new award approved from 1 August 2026 may be filed with one IP, family member or not; the second, making at least one of them a non-family member, must be employed by the end of the basis period of the first year of assessment, or the award is revoked from its start.
| Condition | 13O (SFO) | 13U (SFO) |
|---|---|---|
| AUM in designated investments | ≥ S$20m | ≥ S$50m |
| Investment professionals | ≥2, incl. ≥1 non-family; under FDD Cir 05/2026 a new fund may file with one and complete the team by the end of the first year of assessment | ≥3, incl. ≥1 non-family; under FDD Cir 05/2026 a new fund may file with two and hire the third and the non-family member by the end of the first year of assessment |
| Annual spending | tiered: S$200K–1m, breakpoints S$250m / S$2bn from basis periods ending on or after 1 Aug 2026 | tiered: S$200K–1m, same grid |
| Capital deployment | lower of 10% of AUM / S$10m | lower of 10% of AUM / S$10m |
The immigration layer: EP for the team, ONE Pass for the principal
The IP tax-residency requirement has an immigration dimension: for a foreign hire, the investment professional role at the SFO in practice means an Employment Pass at the office itself — MAS expects the declared IPs to sit in Singapore, not advise remotely.
MOM's bar for financial services and the principal's personal track:
| Pass | Threshold |
|---|---|
| EP, fixed salary in finance (MOM) | from S$6,200 a month |
| EP, ceiling with age | up to S$11,800 a month |
| EP from January 2027 | from S$6,600 a month |
| COMPASS for EP | at least 40 points |
| COMPASS exemption | from S$22,500 a month |
| ONE Pass for the principal (MOM) | from S$30,000 a month |
For a non-family IP the points usually come from C1 (salary against the sector benchmark) and C2 (qualifications), while the ONE Pass is a personal pass not tied to a single employer. The full map of statuses — in the residency article.
Spending and capital deployment
The Tiered Spending Requirement tracks AUM: the minimum for each year of assessment rises with the size of the fund. Under FDD Cir 05/2026 the whole S$200K of the lowest tier must be local business spending; in the S$250m–2bn tier at least S$300K and from S$2bn at least S$500K must be, and the rest may come from eligible donations to Singapore charities and blended-finance grants, with grants recognised at 2x (FDD Cir 05/2026, Annex 6B).
| AUM in designated investments | Basis periods ended before 1 Aug 2026 | Basis periods ending from 1 Aug 2026 (FDD Cir 05/2026) |
|---|---|---|
| < S$50m | S$200K | S$200K |
| S$50–100m | S$500K | S$200K |
| S$100–250m | S$1m | S$200K |
| S$250m – 2bn | S$1m | S$500K |
| ≥ S$2bn | S$1m | S$1m |
The right-hand column binds new awards and existing awards made under the 18 April 2022 and 5 July 2023 conditions; offices that applied before 18 April 2022 keep a flat S$200K of total business spending (FDD Cir 05/2026, Annex 6B).
The Capital Deployment Requirement: invest the lower of 10% of AUM or S$10 million, first by the end of the basis period of the first full year of assessment after the award starts. From basis periods ending on or after 1 August 2026 — for new awards and for existing ones under the 2022 and 2023 conditions — FDD Cir 05/2026 narrows the eligible assets to three options: investments listed on MAS-approved exchanges, investments distributed by MAS-licensed financial institutions in Singapore, and non-listed Singapore companies with an operating business and substantive presence in Singapore. The six categories of the 5 July 2023 framework governed earlier basis periods:
- 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
Under that framework multipliers softened the burden: 2x for SG-listed equities and deeply concessional capital, 1.5x for ETFs and funds mandated on SG-listed equities. Under FDD Cir 05/2026 one 2x multiplier applies to equities on approved exchanges, funds investing substantially in Singapore-listed equities, blended-finance instruments and non-listed Singapore operating companies.
A separate condition is a private banking account with a MAS-licensed financial institution — at submission and throughout the period.
The SFO's own tax position
The 13O exemption covers the fund company, not the manager: the SFO itself is an ordinary Singapore taxpayer, and its management fee from the fund bears corporate income tax at 17% (IRAS). Fund and office are related parties, so the fee must be arm's length: IRAS expects independent-level pricing in related-party dealings and transfer pricing documentation above the thresholds.
The standard construct is cost-plus: the SFO recharges its operating costs to the fund with a mark-up, and for routine support services IRAS accepts a 5% mark-up without benchmarking (IRAS). The practical point: the office's tax base is the mark-up, not the family's assets, so the 17% is rarely material — the real risk is a token fee that fails the arm's length test.
PTIS: a deduction for overseas philanthropy
Since 1 January 2024 families on 13O/13U have had a philanthropic add-on — the Philanthropy Tax Incentive Scheme. A qualifying donor — one whose 13O/13U fund is managed by a qualifying SFO — claims a 100% tax deduction for overseas donations made through qualifying local intermediaries, capped at 40% of the donor's statutory income (MAS, Budget 2023). The intermediary is local: a registered charity with a foreign fundraising permit, a grantmaker under the MCCY scheme or another MAS-approved structure.
In return MAS wants substance on top of the baseline: a philanthropy professional (in-house or outsourced), one more local professional hire (who may be the philanthropy professional) and an additional S$200K of local business spending. The scheme is built for a sustained giving programme, not a one-off donation.
Process and timeline
The path: preliminary submission → review by the FO team at the Financial Centre Development Department → award. Material changes — UBOs, IPs, structure — must be notified to MAS in writing. MAS told Parliament on 24 September 2025 that most family office applications are now processed within three months, down from 12 (MAS).
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.
Source of wealth checks
Since mid-2023 source of wealth has been the least predictable stage of an application. The check runs in two layers: MAS screens the individuals and entities involved against money-laundering, terrorism-financing and adverse-news databases and reviews the SFO's business plan, while the MAS-licensed bank opening the mandatory account assesses whether the structure has a clear and legitimate purpose, identifies the UBOs and corroborates the sources of wealth and funds (MAS). From 1 October 2024 every new application must also carry a screening report from one of the Screening Service Providers listed by MAS, which adds a third layer; the screening generally takes about two weeks (MAS).
The standard pack: audited accounts of the source business, sale and purchase agreements for exits, tax returns, statements tracing the chain of funds. The longer the chain from the original business to investable assets, the further FDD drifts past the three-month target. Sanctions exposure is a sensitivity of its own — it draws the deepest scrutiny, up to parliamentary questions about awards already granted (MAS, 2025). How to assemble the file — in the source-of-funds article.
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.
Q/A
How much AUM does 13O require for an SFO?
S$20 million in designated investments at submission and at the end of every basis period — the grace period was abolished on 5 July 2023, so the threshold cannot be reached after filing; 13U asks S$50 million. Assets outside the designated-investment list — crypto, art, Singapore property — do not count towards the threshold.
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?
Per MAS's written reply to Parliament of 24 September 2025, most applications are now processed within three months, down from twelve. The gating stage is source of wealth: the private bank opening the mandatory account verifies UBOs and funds, MAS screens against money-laundering and adverse-news databases, and since 1 October 2024 an independent screening report from an approved provider adds a third layer.
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 thresholds; the change for them came a year later, in FDD Cir 05/2026 of 31 July 2026: spending breakpoints of S$250m and S$2bn for new awards and, from basis periods ending on or after 1 August 2026, existing ones, a hiring window for investment professionals and a three-option capital deployment requirement.
What are the Section 13O conditions for a single family office in Singapore in 2026?
Five standing conditions: S$20m in designated investments at submission and at the end of each basis period; two investment professionals (one non-family); tiered spending (S$200K/500K/1m by AUM, with breakpoints of S$250m/S$2bn from basis periods ending on or after 1 August 2026 and S$50m/S$100m before); capital deployment (lower of 10% of AUM or S$10m — three asset options under FDD Cir 05/2026 from the same date, six asset categories with multipliers before); a private banking account with a MAS-licensed institution.
Does a Singapore single family office need a fund management licence from MAS?
No, but the mechanics changed on 15 June 2026. MAS replaced case-by-case licensing exemptions with a class exemption: an SFO managing only one family's money takes no licence but must file a Notice of Commencement of Business within 14 days of starting operations, keep an account with a MAS-licensed bank and file an annual return with AUM and bank details. Offices running before that date have until 15 June 2027; the exemption fails if the office manages third-party money or markets its services.