Does Section 13O apply only to Singapore-resident families?

No. Section 13O is open to families regardless of residency, as long as the fund vehicle and the SFO are Singapore-incorporated and the substance conditions are met. Most applicants relocate at least one family decision-maker to Singapore as part of the broader plan, but residency is not itself a Section 13O condition.

How long does MAS take to award Section 13O?

MAS does not publish a service-level commitment for Section 13O review. Applicants who submit a complete package, with the structure in place and the investment professional identified, see review windows that fall in the range of several months. Incomplete packages can extend review materially.

Can the family employ themselves as the investment professional?

A qualifying investment professional must function as a portfolio manager, research analyst, or trader, earn above the MAS-published minimum salary threshold, and spend more than 50 percent of working time on the qualifying activity. A family member who meets all three criteria and is materially employed by the SFO can in principle qualify, subject to MAS review.

What is the relationship between Section 13O and the Philanthropy Tax Incentive Scheme?

They are independent schemes that interact. The Philanthropy Tax Incentive Scheme launched on 1 January 2024 provides eligible single family offices a 100 percent tax deduction for qualifying overseas donations, capped at 40 percent of statutory income. A Section 13O awardee who also meets the philanthropy scheme conditions can use both in the same tax year.

What happens if AUM falls below S$20 million after award?

Section 13O conditions are continuing. A material breach of AUM, business spending, or investment professional conditions can trigger MAS engagement and ultimately withdrawal of the incentive for the affected period. Most awardees treat the conditions as a permanent operating discipline rather than a one-time application threshold.

Is MAS approval transferable if the family restructures?

Section 13O is awarded to the specific fund vehicle. Material restructures of the fund or SFO require notification to MAS and may require a fresh review depending on the substance of the change. Internal share transfers among existing family members are simpler than admitting new beneficial owners.

HowTo

Section 13O Singapore Family Office: 2026 Setup Roadmap

In one sentence

Section 13O setup runs about six months from incorporation to MAS award: structure the fund vehicle and SFO, file the MAS application, hire the investment professional, then operate.

Quick answer

Step 1 — Incorporate the SFO and the fund vehicle as Singapore companies; appoint a resident director and qualified company secretary per ACRA.
Step 2 — Open accounts with a MAS-licensed private bank or qualifying financial institution; the fund holds Designated Investments through this account.
Step 3 — Submit the Section 13O application to MAS through the family office portal, with structure chart, investment policy, and key personnel.
Step 4 — Hire at least one qualifying investment professional earning above the MAS-published minimum and spending the majority of working time on the qualifying activity.
Step 5 — On award, meet the AUM milestone within the grace period and maintain annual business spending and local deployment per the Section 13O conditions.

Why this matters in 2026

MAS published its Response to Feedback on the Proposed Framework for Single Family Offices in 2024, signalling that the Section 13O scheme would be retained as the entry tier alongside Section 13U for larger funds. The 2024 response made clear that MAS expects substance: a real Singapore-incorporated SFO, local hires, ongoing business spending, and deployed local investment. The era of paper structures has ended.

For families considering 2026 setup, three things shape the roadmap. First, MAS streamlined application documentation in 2024 to reduce operational friction, but the underlying substance conditions remain. Second, the climate-related investment and blended finance rules added on 5 July 2023 are still in effect, expanding what counts as eligible investment for Section 13O. Third, the Philanthropy Tax Incentive Scheme launched on 1 January 2024 sits alongside Section 13O and gives qualifying family offices an additional 100 percent tax deduction for overseas donations, capped at 40 percent of statutory income.

A 2026 applicant who structures the SFO with these three layers in mind — substance, expanded eligible investments, and philanthropy — gets through MAS review faster and starts operations on a more durable footing.

The fundamentals

Step 1 — Structuring the SFO and the fund vehicle

Section 13O exempts Specified Income from Designated Investments earned by the fund vehicle from Singapore income tax. The fund and the SFO are two separate Singapore-incorporated companies. The SFO acts as the Singapore-based fund manager; the fund holds the family's investment assets.

ACRA requires every Singapore private limited company to have at least one director ordinarily resident in Singapore and a qualified company secretary appointed within six months of incorporation. The SFO will also be the entity that employs the investment professional under Step 4. The fund vehicle does not need separate employees if the SFO is performing fund management for it under the Section 13O structure.

Most families set up both companies before filing the Section 13O application; MAS expects the structure chart to be in place at the time of submission.

Step 2 — Banking and Designated Investments custody

Section 13O requires the fund vehicle to hold Designated Investments. The MAS list of Designated Investments covers most listed and unlisted equities, debt securities, units in collective investment schemes, financial derivatives, and selected alternatives. As of 5 July 2023, climate-related investments and blended finance structures are recognised as eligible investments under Sections 13O and 13U.

To custody Designated Investments and demonstrate sufficient local economic activity, the fund opens an account with a MAS-licensed private bank or a qualifying financial institution. MAS uses the institution relationship as one signal of substance during application review, although it is not a formal Section 13O criterion in the published infographic.

Banking onboarding for non-resident families runs four to ten weeks; families should treat this as a critical-path step that runs in parallel with incorporation rather than after MAS award.

Step 3 — MAS application: investment policy, structure chart, and key personnel

The Section 13O application is made to MAS through the dedicated single family office portal that consolidated the application channel in 2024. The package includes the fund and SFO structure chart, the investment policy and mandate, the AUM commitment, the investment professional hire plan, and family beneficial ownership disclosures.

MAS's published guidance is that Section 13O applicants meet a minimum Designated Investments AUM of S$20 million; an applicant who is below that threshold at application can be awarded with a Designated Investments AUM of S$10 million provided the fund reaches S$20 million by the end of a two-year grace period. The fund must commit to a minimum local deployment, which the MAS infographic articulates as 10 percent of AUM or S$10 million, whichever is lower, in qualifying capital deployment categories such as equities listed on the Singapore Exchange, qualifying debt securities, funds distributed by Singapore-licensed managers, and private credit to non-listed Singapore-incorporated companies.

Annual business spending is part of the award conditions; the MAS infographic specifies a minimum business spending floor that scales with AUM size, with the local spending recognised including local employment costs and approved professional services.

	Condition	Section 13O (Entry)
Minimum Designated Investments AUM	S$20 million (S$10M at application, S$20M by end of two-year grace period)	Higher tier — applicants substantially above S$50 million
Minimum investment professionals	At least 1 qualifying investment professional	At least 3 qualifying investment professionals
Minimum annual business spending	Tiered floor scaling with AUM	Higher floor scaling with AUM
Local deployment requirement	10 percent of AUM or S$10 million, whichever is lower	Local deployment scales with AUM
Application route	MAS Single Family Office portal	MAS Single Family Office portal

Common pitfalls

Treating the SFO and the fund as one company
Section 13O is a fund tax incentive: the fund vehicle is the entity whose Specified Income is exempt. Structuring everything in one company forces a restructure during application review and delays the award.
Hiring the investment professional after award rather than before
MAS expects the investment professional to be in place when reviewing the structure. Applicants who plan to hire only after award risk a longer review or a conditional approval that defers the tax incentive start date.
Underestimating banking onboarding time for non-resident families
Private bank onboarding for first-time Singapore families runs four to ten weeks. Treating this as a post-award step adds months to first investment activity and strands AUM in transit.
Counting non-Designated Investments toward the AUM milestone
The MAS list of Designated Investments is finite. Direct holdings of operating businesses, residential property, and certain alternatives sit outside the list and do not count toward the AUM milestone, even if held inside the fund.

Frequently asked questions

Does Section 13O apply only to Singapore-resident families?: No. Section 13O is open to families regardless of residency, as long as the fund vehicle and the SFO are Singapore-incorporated and the substance conditions are met. Most applicants relocate at least one family decision-maker to Singapore as part of the broader plan, but residency is not itself a Section 13O condition.
How long does MAS take to award Section 13O?: MAS does not publish a service-level commitment for Section 13O review. Applicants who submit a complete package, with the structure in place and the investment professional identified, see review windows that fall in the range of several months. Incomplete packages can extend review materially.
Can the family employ themselves as the investment professional?: A qualifying investment professional must function as a portfolio manager, research analyst, or trader, earn above the MAS-published minimum salary threshold, and spend more than 50 percent of working time on the qualifying activity. A family member who meets all three criteria and is materially employed by the SFO can in principle qualify, subject to MAS review.
What is the relationship between Section 13O and the Philanthropy Tax Incentive Scheme?: They are independent schemes that interact. The Philanthropy Tax Incentive Scheme launched on 1 January 2024 provides eligible single family offices a 100 percent tax deduction for qualifying overseas donations, capped at 40 percent of statutory income. A Section 13O awardee who also meets the philanthropy scheme conditions can use both in the same tax year.
What happens if AUM falls below S$20 million after award?: Section 13O conditions are continuing. A material breach of AUM, business spending, or investment professional conditions can trigger MAS engagement and ultimately withdrawal of the incentive for the affected period. Most awardees treat the conditions as a permanent operating discipline rather than a one-time application threshold.
Is MAS approval transferable if the family restructures?: Section 13O is awarded to the specific fund vehicle. Material restructures of the fund or SFO require notification to MAS and may require a fresh review depending on the substance of the change. Internal share transfers among existing family members are simpler than admitting new beneficial owners.

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