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 at least the first qualifying Investment Professional identified, see review windows that fall in the range of several months. Incomplete packages can extend review materially.

How many Investment Professionals does the Section 13O scheme require under the post-1 January 2025 framework?

The post-2025 Section 13O framework requires at least two qualifying Investment Professionals employed throughout the basis period. If only one IP is in place at application, the second IP must be hired within a one-year grace period. Each IP 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.

How is AUM measured for Section 13O under the post-1 January 2025 framework?

The Section 13O AUM gate is measured by the value of the fund's investments in Designated Investments rather than by Net Asset Value. The minimum threshold is S$20 million at award; an applicant below that threshold at application can be awarded at S$10 million in Designated Investments provided the fund reaches S$20 million by the end of a two-year grace period.

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 in Designated Investments falls below S$20 million after award, or one of the two Investment Professionals departs?

Section 13O conditions are continuing. A material breach of the AUM-in-Designated-Investments threshold, the two-IP minimum, the tiered local business spending floor, or the local deployment condition can trigger MAS engagement and ultimately withdrawal of the incentive for the affected period. Most awardees treat the post-2025 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 under the post-1 January 2025 framework runs about six months from incorporation to MAS award: structure the fund vehicle and SFO, file the MAS application, hire two qualifying Investment Professionals (one-year grace for the second IP when only one is in place at application), 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 two qualifying Investment Professionals earning above the MAS-published minimum and spending the majority of working time on the qualifying activity; if only one IP is in place at application, the second IP must be hired within a one-year grace period under the post-1 January 2025 framework.
Step 5 — On award, meet the AUM milestone in Designated Investments within the two-year grace period and maintain annual local business spending and local deployment per the Section 13O conditions.

Why this matters in 2026

MAS refreshed the Section 13O qualifying conditions with effect from 1 January 2025, materially changing both the personnel and AUM mechanics that shape any 2026 setup. The post-2025 framework requires at least two Investment Professionals employed throughout the basis period for Section 13O funds, with a one-year grace period for the second IP when only one is in place at application. The AUM definition was restated to refer to the value of the fund's investments in Designated Investments, replacing the earlier Net Asset Value formulation. These changes are documented in the MAS Response to Feedback on the Proposed Framework for Single Family Offices and the MAS Section 13O and 13U Tax Incentives Infographic.

Beyond the 1 January 2025 changes, three further layers shape the 2026 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 the post-2025 personnel and AUM definitions, the expanded eligible investments, and the philanthropy layer in mind gets through MAS review faster and starts operations on a more durable footing. Families whose AUM profile or mandate pushes beyond the entry tier should also weigh [Section 13U, the enhanced tier](/insights/section-13u-singapore-family-office-aum) on the same substance dimensions, and a side-by-side mapping across the three schemes is in [13O, 13U, and Philanthropy Tax Incentive compared](/comparisons/family-office-tax-schemes-13o-13u-13z).

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 two Investment Professionals required under Step 4 of the post-1 January 2025 framework. 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.

Under the post-1 January 2025 framework, the Section 13O AUM gate is measured by the value of the fund's investments in Designated Investments rather than by Net Asset Value. MAS's published guidance is that Section 13O applicants meet a minimum AUM of S$20 million in Designated Investments; an applicant who is below that threshold at application can be awarded at S$10 million in Designated Investments 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.

The post-2025 framework also requires at least two qualifying Investment Professionals employed throughout the basis period; if only one IP is in place at application, the second IP must be hired within a one-year grace period. A qualifying IP earns above the MAS-published minimum salary, functions as a portfolio manager, research analyst, or trader, and spends more than 50 percent of working time on the qualifying activity.

Annual local business spending is part of the award conditions; the MAS infographic specifies a tiered floor that scales with AUM size: S$200,000 per year for AUM under S$50 million, S$500,000 per year for AUM between S$50 million and S$100 million, and S$1 million per year for AUM at or above S$100 million. The recognised local spending includes Investment Professional and operational staff costs, Singapore-based legal, audit, tax, fund administration, corporate secretarial, MAS licensing fees, office rent, and Singapore IT spend.

	Condition	Section 13O (Entry)
Minimum AUM in Designated Investments (post-1 January 2025 definition)	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 (post-1 January 2025 framework)	At least 2 qualifying Investment Professionals employed throughout the basis period; one-year grace for the second IP when only one is in place at application	At least 3 qualifying Investment Professionals
Minimum annual local business spending	S$200,000 (AUM < S$50M) / S$500,000 (S$50M – S$100M) / S$1,000,000 (≥ S$100M)	Higher tier 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.
Planning for one Investment Professional under the post-1 January 2025 framework
The post-2025 framework requires at least two Investment Professionals employed throughout the basis period for Section 13O funds. The one-year grace period for the second IP applies only when one IP is already in place at application; it is not a permanent waiver. Families that plan a single-IP setup beyond the grace window risk award withdrawal and miss the second IP cost line in year-one budget.
Hiring the Investment Professionals after award rather than before
MAS expects at least the first qualifying 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
Under the post-1 January 2025 framework, the Section 13O AUM gate is measured by the value of the fund's investments in Designated Investments rather than by Net Asset Value. 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 at least the first qualifying Investment Professional identified, see review windows that fall in the range of several months. Incomplete packages can extend review materially.
How many Investment Professionals does the Section 13O scheme require under the post-1 January 2025 framework?: The post-2025 Section 13O framework requires at least two qualifying Investment Professionals employed throughout the basis period. If only one IP is in place at application, the second IP must be hired within a one-year grace period. Each IP 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.
Can a family member serve as one of the qualifying Investment Professionals?: A family member who functions as a portfolio manager, research analyst, or trader, earns above the MAS-published minimum salary threshold, and spends more than 50 percent of working time on the qualifying activity can in principle qualify as one of the two required Investment Professionals, subject to MAS review. The second IP slot is most often filled by a non-family hire.
How is AUM measured for Section 13O under the post-1 January 2025 framework?: The Section 13O AUM gate is measured by the value of the fund's investments in Designated Investments rather than by Net Asset Value. The minimum threshold is S$20 million at award; an applicant below that threshold at application can be awarded at S$10 million in Designated Investments provided the fund reaches S$20 million by the end of a two-year grace period.
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 in Designated Investments falls below S$20 million after award, or one of the two Investment Professionals departs?: Section 13O conditions are continuing. A material breach of the AUM-in-Designated-Investments threshold, the two-IP minimum, the tiered local business spending floor, or the local deployment condition can trigger MAS engagement and ultimately withdrawal of the incentive for the affected period. Most awardees treat the post-2025 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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