Comparison · L2
Singapore Family Office Tax Schemes Compared (2026): 13O, 13U, and Philanthropy
Section 13O is the entry-tier fund tax incentive; Section 13U is the enhanced tier with three investment professionals; the Philanthropy Tax Incentive Scheme is a separate 100 percent deduction for qualifying overseas donations.
Top 5
- Section 13O — entry tier; minimum S$20M Designated Investments AUM; at least 1 qualifying investment professional; 10% or S$10M (whichever lower) deployed locally.
- Section 13U — enhanced tier; same MAS published AUM floor as 13O but practical applicants substantially larger; at least 3 qualifying investment professionals (≥1 non-family); higher business spending floor.
- Philanthropy Tax Incentive Scheme — independent scheme launched 1 Jan 2024; 100 percent deduction for qualifying overseas donations capped at 40 percent of statutory income.
- A 13O or 13U awardee that meets the philanthropy scheme conditions can use both in the same tax year.
- Choosing wrongly means either over-capitalising for 13U conditions (cost) or hitting 13O ceilings and being forced to migrate (operational disruption).
Side-by-side comparison
| Section 13O | Section 13U | Philanthropy Tax Incentive Scheme | |
|---|---|---|---|
| Type | Fund tax incentive (entry tier) | Fund tax incentive (enhanced tier) | Charitable donation deduction scheme |
| Administering body | MAS | MAS | MAS |
| Headline benefit | Tax exemption on Specified Income from Designated Investments at fund-vehicle level | Same exemption, enhanced-tier substance bar | 100% tax deduction for qualifying overseas donations, capped 40% statutory income |
| Minimum AUM | S$20M Designated Investments (S$10M at application, S$20M by Year 2) | Same MAS floor; in practice substantially larger | No AUM threshold; tied to qualifying SFO status |
| Investment professionals | At least 1 qualifying | At least 3 (≥1 non-family) | Not directly required |
| Local capital deployment | 10% AUM or S$10M, whichever lower | Higher tier than 13O | Not applicable to donation scheme |
| Launch date | Long-standing | Long-standing | 1 January 2024 |
Methodology
Detailed analysis
Section 13O — Onshore Fund Tax Incentive (Entry Tier)
Best for: Single family offices with S$20M to S$50M AUM, single-strategy mandate, willing to hire one qualifying investment professional and meet entry-tier substance.
Pros
- Lower investment-professional headcount requirement (1 versus 3 for 13U).
- Lower annual business spending floor than 13U.
- Same Specified Income exemption scope as 13U at the fund-vehicle level.
Cons
- Substance conditions are continuing — slipping below conditions in any year affects exemption for that period.
- Migration to 13U later requires fresh MAS application; no automatic upgrade.
- Direct holdings of operating businesses and residential property sit outside Designated Investments.
Cost: Engagement scope and pricing scoped per case during the strategy call.
Source: MAS — Fund Tax Incentive Scheme for Family Officesverified 2026-05-02
Section 13U — Enhanced Tier Fund Tax Incentive
Best for: Single family offices with multi-strategy mandate, S$50M+ AUM, comfortable with 3 investment professionals (≥1 non-family) and higher business spending.
Pros
- Same Specified Income exemption scope as 13O at the fund-vehicle level.
- Multi-professional team supports multi-strategy mandate without added administrative burden.
- Brand and operational signal alignment for larger AUM families.
Cons
- Higher annual business spending floor — material if AUM is small relative to operating cost.
- At least one of three professionals must be non-family — affects family-only operating models.
- Substance conditions binding throughout incentive period.
Cost: Engagement scope and pricing scoped per case during the strategy call.
Source: MAS — Section 13O & 13U Infographicverified 2026-05-02
Philanthropy Tax Incentive Scheme (PTIS) — launched 1 January 2024
Best for: Qualifying single family offices (existing 13O or 13U awardees in most observed cases) seeking to formalise overseas philanthropic activity in a tax-efficient frame.
Pros
- 100% tax deduction for qualifying overseas donations.
- Caps at 40% of statutory income — substantial deduction headroom for high-income years.
- Stackable with 13O / 13U awards — same tax year, same SFO.
Cons
- Conditions independent of 13O / 13U — must be separately satisfied.
- Overseas donation pathways need recipient-vetting consistent with MAS expectations on philanthropic substance.
- Cap calculation requires tracking statutory income — adds compliance overhead.
Cost: Engagement scope and pricing scoped per case during the strategy call.
Source: MAS — Philanthropy Tax Incentive Scheme for Family Officesverified 2026-05-02
Decision framework
AUM is S$20M to S$50M and the mandate is single-strategy?
Section 13O is the right entry — lower headcount, lower spending floor, same exemption scope.
AUM is above S$50M and the mandate spans equities, credit, and venture?
Section 13U fits — three-professional team supports multi-strategy without added overhead.
The family runs material overseas philanthropic activity?
Layer PTIS on top of the chosen fund tax incentive — independent scheme, stackable in the same tax year.
Direct holdings include operating businesses or residential property?
Those holdings sit outside Designated Investments — the fund tax incentive does not exempt them; structure separately.
Frequently asked questions
- Is Section 13O still available for new applicants in 2026?
- Yes. Section 13O is the published entry-tier framework and remains open for new applications. MAS's 2024 framework refinements and the 2024 consultation response confirmed retention of both 13O and 13U.
- Can a Section 13O awardee migrate to Section 13U?
- Yes, in principle, but the migration is treated as a fresh application against 13U conditions. There is no automatic upgrade pathway, and the family must demonstrate that 13U substance conditions are met at the time of conversion.
- Does the Philanthropy Tax Incentive Scheme apply to local Singapore donations?
- PTIS is specifically targeted at qualifying overseas donations. Local Singapore donations to Institutions of a Public Character (IPCs) attract their own deduction under the standard tax framework.
- How does the GIP family office route relate to 13O / 13U?
- GIP is a permanent residence pathway administered by EDB / Contact Singapore, separate from the MAS fund tax incentives. A family pursuing PR through GIP can also apply for 13O or 13U on the same fund vehicle, provided each set of conditions is independently met.
- What happens if the fund's AUM falls below S$20M after award?
- Section 13O / 13U conditions are continuing. A material drop in AUM, business spending, or investment professional headcount can trigger MAS engagement and ultimately withdrawal of the incentive for the affected period. Most awardees treat the conditions as a permanent operating discipline.
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