TRW & Co · Private Wealth & Family
Family Offices in Singapore
A family office in Singapore lets one family manage its investments through a Singapore company, usually with a tax-exempt fund and a trust above it. In 2026 MAS introduced a single licensing exemption with notification and reporting duties, and refined the 13O and 13U incentive conditions. This guide explains the rules, the structures and the steps.
Key pointSince 15 June 2026 a single family office relies on one MAS class exemption that requires notification within 14 days of starting business, and the exemption is lost if the office manages any money from outside the defined family circle.
At a glance
One licensing exemption
From 15 June 2026 a harmonised MAS class exemption covers single family offices that manage only family money; offices already operating must file by 15 June 2027.
Notify within 14 days
A new single family office must notify MAS within 14 days of commencing business, then file an annual return stating its assets and MAS-licensed bank.
13O and 13U minimums
Single family office funds need S$20 million (13O) or S$50 million (13U) in designated investments, tested at application and each financial year end.
Non-family professional
At least one investment professional must be outside the family; from August 2026 funds may apply with fewer and hire the rest within the first award year.
Schemes run to 2029
The 13D, 13O and 13U fund tax incentive schemes are currently extended to 31 December 2029, with conditions set and updated by MAS circular.
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What setting up a family office in Singapore involves
A family office in Singapore is a private structure that manages the investments, and often the wider affairs, of one wealthy family. Most are single family offices: a Singapore-incorporated management company that invests money belonging to members of one family, usually through a separate fund vehicle. A multi-family office serves several unrelated families and is treated as a commercial fund manager.
The legal work sits at the meeting point of four regimes. The Securities and Futures Act decides whether the office needs a licence. The Income Tax Act decides whether the fund's investment gains are exempt. Immigration rules decide who can relocate to run it. Trust, company and succession law decide who ultimately owns and controls the wealth when the founding generation steps back.
Families usually call a lawyer at one of three moments: when they first compare Singapore with Dubai, Hong Kong, London or Switzerland; when the bank or the Monetary Authority of Singapore (MAS) asks questions the family cannot answer; or when the next generation starts to disagree about how the money should be run. Each moment is easier if the structure was designed with the others in mind.
Licensing: the 2026 single family office exemption
Managing money for others is a regulated activity under the Securities and Futures Act 2001. A single family office has never been expected to hold a capital markets services licence for fund management, but until recently the basis for that position varied from office to office. MAS has now replaced the patchwork with one harmonised class exemption, which, according to its media release on the revised framework, took effect on 15 June 2026.
Who qualifies for the exemption
Broadly, the office must be incorporated in Singapore and must manage money only for family members, family trusts and wholly family-owned companies, charities funded exclusively by the family, and a small group of key employees. It must be funded exclusively by the family and those key employees. MAS's guidance caps the key employees' share at a minority, and their assets must stay a small fraction of the office's total assets under management.
"Family" is defined generously. The MAS FAQs on the exemption framework work from a common ancestor across several generations and include spouses, former spouses, adopted children and step-children, and certain in-laws. Ownership can sit in trusts, foundations or other holding vehicles, so the framework does not force a family to dismantle an existing structure.
Notification, banking and annual returns
A new office must notify MAS within 14 days of commencing business, and an office that was already operating before 15 June 2026 has until 15 June 2027 to file a notice of continuation. Each office must keep an account with a MAS-licensed bank, file an annual return stating its assets under management and its bank, and maintain a Singapore-resident point of contact employed by the office.
The exemption comes with a marketing restriction. Under Notice SFA 04-N07, an exempt office must not suggest that it is licensed, regulated or supervised by MAS. Websites, pitch decks and email footers that describe the office as "MAS-regulated" are a compliance risk in their own right.
The exemption fails the moment the office manages money for someone outside the family circle, such as a friend's family or a co-investor, or markets its services. If a family wants to take outside capital, it should plan a separate licensed or registered manager before the first conversation, not after.
Tax incentives for a family office in Singapore: 13O, 13U and 13D
Singapore taxes companies on income, and investment gains realised by a fund vehicle can be taxable unless an exemption applies. The fund tax incentive schemes in the Income Tax Act 1947 exempt "specified income" from "designated investments" for approved funds. For a family office in Singapore, the two schemes that matter are section 13O, for a Singapore-resident fund company, and section 13U, the enhanced-tier scheme that is open to vehicles wherever they are constituted. A newer section 13OA extends the 13O approach to Singapore limited partnerships. Section 13D, the offshore fund scheme, is self-administered and rarely the centrepiece of a family structure.
The schemes currently run until 31 December 2029. Approval is by MAS, applications go through a preliminary submission, and since late 2024 an application must be supported by a screening report on the family from a provider on MAS's list. Expect detailed questions about the source of wealth.
The conditions that apply to single family office funds
MAS refined the conditions for single family office funds by circular in July 2026, with most changes applying to new awards from 1 August 2026 and to existing awards from the year of assessment in which the basis period ends on or after that date. The table summarises the main tests as reported by advisers who have reviewed the circular. Confirm the current version with MAS before relying on any figure.
| Condition | Section 13O / 13OA | Section 13U |
|---|---|---|
| Minimum assets in designated investments | S$20 million, tested at application and at each financial year end | S$50 million, tested at application and at each financial year end |
| Investment professionals | At least two, at least one a non-family member; may apply with one and hire the second by the end of the first award year | At least three, at least one a non-family member; may apply with two and hire the third by the end of the first award year |
| Local business spending (tiered) | S$200,000 where assets are below S$250 million; S$500,000 from S$250 million to below S$2 billion; S$1 million at S$2 billion or more | |
| Capital deployment | The lower of 10% of assets or S$10 million in qualifying investments: Singapore-exchange listed securities, investments distributed by Singapore-licensed institutions, or non-listed Singapore operating companies | |
| Banking | Private banking account with a MAS-licensed institution, at application and throughout | |
Two refinements matter in practice. The asset test is now a snapshot at year end rather than a continuous requirement, which helps families with volatile portfolios. And the capital deployment test has been simplified, with some investments, such as Singapore-listed equities and qualifying blended finance, counting at twice their value.
Philanthropy alongside the office
Families that give abroad should also look at the Philanthropy Tax Incentive Scheme for family offices, which was announced in Budget 2023 and is administered by MAS. It allows a deduction for qualifying overseas donations made through approved local intermediaries, subject to a cap. Our charities and philanthropy page covers the charitable side.
Choosing the structure
A typical single family office in Singapore has two layers: a management company that employs the team and holds the licensing exemption, and one or more fund vehicles that hold the investments and apply for the tax incentive. Above them sits the ownership layer, which is where succession is decided.
Private company fund
The classic 13O vehicle is a Singapore-incorporated company owned by the family's holding structure. It is familiar to banks and auditors, and the share register makes control easy to evidence.
Variable capital company
A VCC offers umbrella sub-funds with segregated assets and a non-public register of members. It suits families running several strategies or generations' pools. See our variable capital companies page.
Limited partnership
Since the 13OA scheme, a Singapore limited partnership can hold investments with the exemption applied at partnership level. It suits families used to general partner and limited partner economics.
Trust or foundation on top
A discretionary trust, often with a private trust company as trustee, holds the shares in the management company and fund. This is the layer that answers "what happens when the founder dies?"
The trust layer deserves as much attention as the fund. Our guide to trusts and succession planning explains how Singapore trusts work, and our article on family investment vehicles compares the holding options in more depth.
The tax incentive is the reason families choose Singapore; the ownership layer is what decides whether the structure survives the next generation.
The set-up process, step by step
- Define the family and the purpose. List who counts as family, who funds the office and who will benefit. This drives both the licensing exemption and the trust design.
- Source-of-wealth file. Assemble the history of how the wealth was made, with documents. Banks, MAS and the screening provider will all ask, and inconsistencies slow everything.
- Incorporate the management company and fund vehicles. Register with ACRA, adopt constitutions that reflect the family's governance, and appoint directors who can genuinely run the office from Singapore.
- Open banking relationships. Open the private banking account with a MAS-licensed institution early; onboarding is often the longest single step.
- Hire investment professionals. Recruit at least the minimum team, including a non-family professional, and secure their Employment Passes.
- Notify MAS and apply for the tax incentive. File the notice of commencement within 14 days of starting business, then make the preliminary submission for the 13O or 13U award with the screening report.
- Fund and deploy. Transfer assets, meet the year-end asset test and plan the capital deployment so it is met by the end of the first full year.
- Run the compliance calendar. Annual returns to MAS, incentive reporting, tax filings, business spending tracking and changes of investment professionals all need an owner.
Documents and evidence to prepare
A well-prepared file is the most effective way to shorten the timetable for a family office in Singapore. MAS and the banks are not looking for perfection; they are looking for a consistent story backed by documents.
- Family tree identifying each family member, their residence and their nationality.
- Source-of-wealth narrative with supporting evidence: company accounts, sale agreements, inheritance documents and tax returns.
- Structure chart showing the management company, fund vehicles, holding companies and any trust or foundation.
- Constitutions, trust deeds, shareholder agreements and any family constitution or charter.
- Business plan: investment strategy, projected assets, staffing, Singapore spending and the capital deployment plan.
- CVs, employment contracts and pass applications for investment professionals.
- Board minutes and policies on conflicts, valuation and related-party dealings.
Risks and common mistakes
Treating the tax incentive as the whole project
Families sometimes design everything around the 13O or 13U conditions and leave ownership, governance and succession for later. The result is a tax-efficient fund that nobody can control once the founder is gone, or that becomes the subject of a sibling dispute. Design the ownership and decision-making layer at the same time. Decide who appoints the directors of the management company, who can change the investment mandate and what happens on death or incapacity. These are the questions that cause expensive litigation when they are left to chance, and they are much cheaper to answer while everyone still agrees.
Letting outside money in by the back door
The licensing exemption depends on the office managing only family money. A friend's co-investment, a family member's business partner joining a deal or a former in-law staying in the fund after a divorce can all raise questions. Check the MAS definition of family before admitting anyone, keep a register of who is invested and why they qualify, and take advice before any new money comes in. If outside capital is part of the long-term plan, a separately licensed or registered manager is usually the cleaner answer. Our capital markets services licensing page explains that route.
Investment professionals who do not meet the test
MAS expects investment professionals to be genuinely engaged in portfolio management, research or trading, to be paid accordingly and to be based in Singapore. A family member with a title but no real role, or a professional who spends most of the year managing the family's operating business, may not count. The non-family requirement is also easy to lose when a key hire resigns. Build a succession plan for the investment team and diarise the deadlines that apply if numbers drop, so that a resignation does not quietly put the award at risk.
Under-documented source of wealth
Most delays come from source-of-wealth gaps rather than from the incentive conditions. Wealth built decades ago through private businesses, often in jurisdictions with patchy public records, needs careful reconstruction. Assemble the evidence before you approach banks, and make sure the narrative given to the bank, the screening provider and MAS is identical. Inconsistent answers about when a business was sold, or who owned it, create far more difficulty than a candid explanation of a gap. Our guide to anti-money laundering sets out what institutions look for.
Forgetting the personal tax and residence picture
The fund may be exempt, but the family members are taxed where they live. A principal who relocates to Singapore may still be tax resident elsewhere, and the home country may have controlled foreign company or exit tax rules that reach the structure. Distributions from the trust or fund to family members abroad also need analysis in their country of residence. Coordinate Singapore advice with home-country tax counsel from the start, and look at our tax residence guide before anyone moves.
People, relocation and governance
A single family office in Singapore needs people on the ground. Investment professionals usually hold Employment Passes, which are assessed under the Ministry of Manpower's framework; our Employment Pass applications page explains the process. Principals who want long-term residence often look at the Economic Development Board's Global Investor Programme, which has its own family office route with demanding investment and asset criteria that change from time to time, or at permanent residence.
Governance is the other half. Many families adopt a written family charter setting out values, the role of the office, how family members can work in it and how disputes are resolved. A charter is not usually legally binding, but the decisions it records can be built into binding documents: the trust deed, the company constitution and shareholder agreements. Our article on family governance goes further.
Cross-border angle: Bangladesh, the UK, the UAE and China
Most families who establish a family office in Singapore hold assets, businesses and family members in several countries. The Singapore structure has to be lawful and workable in each of them.
For Bangladeshi families, outward remittance of capital is controlled under the country's foreign exchange regime, and moving money to fund a Singapore vehicle needs a lawful route, which TRW & Co's Dhaka team can review. For UK-connected families, the end of the remittance basis and the new residence-based regime have changed the calculation for anyone who is or was UK resident. Families with roots in the UAE often compare Singapore with a DIFC or ADGM structure and sometimes use both. Chinese families face outbound investment and reporting rules at home.
TRW & Co coordinates these strands through its offices in Dhaka, London, Dubai and China, and works with tax advisers in each jurisdiction. Our article on wealth structuring explains how the pieces fit, and our double tax treaty page covers treaty access.
How TRW & Co helps families
We advise on design, documentation and coordination. Where Singapore court or tribunal representation is required, we work alongside Singapore-qualified counsel, and we work with licensed tax advisers on tax filings and computations.
Feasibility and comparison
We compare Singapore with the family's other options, map the licensing, tax and immigration conditions against the family's actual assets and people, and give a reasoned recommendation.
Structure and documents
We design the management company, fund vehicles and ownership layer, and prepare constitutions, trust deeds, investment management agreements and governance documents.
MAS process support
We help assemble the source-of-wealth file, the MAS notification and the incentive submission, and coordinate with banks and the screening provider so the story is consistent.
Ongoing compliance and succession
We build the compliance calendar, review changes in family membership or staffing against the conditions, and keep wills, trusts and governance documents aligned as the family changes.
For the investment side, see our investment funds and tax structuring pages, or browse all our practices. To discuss a family office in Singapore in confidence, contact us.
Checklist for families and their advisers
- Is every person who will invest through the office within MAS's definition of family, and is that recorded?
- Do we have a documented, consistent source-of-wealth narrative ready for the bank, the screening provider and MAS?
- Have we chosen between 13O, 13OA and 13U based on projected assets, staffing and spending, not just the headline minimum?
- Do we have, or can we hire, the required investment professionals, including a non-family member?
- Is there a plan to meet the capital deployment requirement by the end of the first full year?
- Who controls the management company and the fund if the founder dies or loses capacity, and is that written into the trust and constitutional documents?
- Has home-country tax advice been taken for every family member who will benefit?
- Is the MAS notice of commencement or continuation diarised, with an owner for the annual return?
Families that answer these questions before incorporating usually find that establishing a family office in Singapore is a structured, predictable project rather than a series of surprises.
Frequently asked questions
01Does a single family office in Singapore need a MAS licence?
Generally no, provided it fits the class exemption that took effect on 15 June 2026. The office must be incorporated in Singapore, manage money only for family members, family-owned vehicles, family-funded charities and a limited number of key employees, and be funded by them. It must notify MAS within 14 days of starting business, bank with a MAS-licensed bank and file an annual return. If it manages outside money or markets its services, it falls outside the exemption and needs a licence or a different structure.
02What is the difference between 13O and 13U?
Both exempt specified income from designated investments for an approved fund. Section 13O is for a Singapore-incorporated, Singapore-resident fund company and has a lower asset threshold, currently S$20 million for single family office funds. Section 13U is the enhanced tier, open to fund vehicles wherever constituted, with a higher threshold of S$50 million and a larger investment team. Section 13OA extends the 13O approach to Singapore limited partnerships. The right choice depends on projected assets, staffing and where the family wants the fund to sit.
03How many investment professionals must we employ?
For single family office funds, MAS requires at least two qualifying investment professionals under 13O and at least three under 13U, with at least one non-family member in each case. Under the refinements applying from 1 August 2026, a 13O fund may apply with one and hire the second by the end of the first award year, and a 13U fund may apply with two. The professionals must genuinely work on portfolio management, research or trading, and MAS sets pay and residence expectations.
04How long does it take to set up a family office in Singapore?
Incorporation itself is quick. The longer steps are bank onboarding, recruiting investment professionals and securing their passes, and the MAS tax incentive review, which turns largely on the quality of the source-of-wealth file. Families with well-documented wealth and a clear structure move considerably faster than those that need to reconstruct records. Plan for several months end to end, and start the banking and documentation work in parallel rather than one after the other.
05Can a family office invest for friends or business partners?
Not under the single family office exemption. The exemption only covers money from family members, family trusts and wholly family-owned companies, family-funded charities and a small group of key employees, within MAS caps. Managing a friend's or partner's money is fund management for third parties, which generally needs a capital markets services licence or another recognised route. If co-investment is part of the plan, structure it through a separately licensed or registered manager or a direct co-investment without the office managing the partner's money.
06Does the family office structure help with succession?
Only if it is designed to. The management company and fund are investment tools; succession depends on who owns and controls them. Most families place the shares in a discretionary trust, often with a private trust company as trustee, and record governance rules in the trust deed, constitutions and a family charter. Wills, lasting powers of attorney and letters of wishes should be updated so that they match the structure, and the documents should be reviewed whenever the family changes.
07Will moving our family office to Singapore change our tax at home?
Possibly. The fund exemption only deals with Singapore tax on the fund. Family members remain taxable in their country of residence, and some countries tax foreign companies or trusts controlled by residents, or tax people who leave. Distributions to family members abroad may also be taxed where they live. Take home-country advice before moving assets or people, and coordinate it with the Singapore structure so that the same facts are presented consistently in each place.
Sources and official materials
- MAS: Wealth management — MAS overview of Singapore's wealth management and family office sector
- MAS media release: revised framework for single family offices — Class exemption effective 15 June 2026
- MAS FAQs on the licensing exemption framework for single family offices — Definition of family, conditions and notification
- MAS Notice SFA 04-N07 — Prohibited representations by exempt persons
- Income Tax Act 1947 — Sections 13D, 13O, 13OA and 13U fund tax incentives
- Securities and Futures Act 2001 — Licensing of fund management in Singapore
General information only, current as at 20 October 2026. It is not legal advice and does not create a lawyer–client relationship. Singapore law and regulatory practice change; check current official sources and take advice on the facts of your matter.
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