Section 13O vs 13U Singapore — Family Office Tax Schemes Compared

For single-family-office funds awarded on or after 1 August 2026, Section 13O (formerly 13R) needs a Singapore-incorporated company or Singapore-registered limited partnership (13OA) as the fund, at least S$20 million of AUM and 2 qualifying investment professionals. Section 13U (formerly 13X) allows a fund in any jurisdiction, including approved master-feeder or SPV structures, and needs at least S$50 million of AUM and 3 investment professionals. Both require at least 1 non-family professional, the same tiered local spending of S$200,000 to S$1 million a year, capital deployment of the lower of 10% of AUM or S$10 million, and MAS approval. Both grant a tax exemption on specified income.

It depends on AUM and structure. Below S$50 million of AUM only 13O is available. At S$50 million or more either scheme can apply: 13U needs a third investment professional (2 at application instead of 1) but lets the fund sit in any jurisdiction, while 13O needs a Singapore company or limited partnership and a Singapore fund administrator. Local spending and capital deployment conditions are the same for both.

A 13U award is a separate MAS award, so moving from 13O to 13U means applying to MAS and meeting the 13U conditions — including S$50 million of AUM and 2 qualifying investment professionals at the point of application. Confirm the mechanics of relinquishing the 13O award with a Singapore tax adviser.

Yes, both. For single-family-office funds awarded on or after 1 August 2026, 13O requires 2 qualifying investment professionals and 13U requires 3; in both, at least 1 must not be a family member of the fund's beneficial owners. The first professionals (1 for 13O, 2 for 13U) must be employed at application and may be family members; the full team must be in place by the end of the award's first financial year, otherwise the award is revoked from its start date. A qualifying professional is a Singapore tax-resident portfolio manager, research analyst or trader paid more than S$3,500 a month.

Minimum local spending is the same for 13O and 13U single-family-office funds and is tiered by AUM at each financial year-end: S$200,000 where year-end AUM is below S$250 million; S$500,000 from S$250 million to below S$2 billion (at least S$300,000 of it local business spending); S$1 million at S$2 billion or more (at least S$500,000 local business spending). Local business spending means: Operating expenses — remuneration, fund management fees and other operating costs — paid to contracting parties in Singapore. Above the lowest tier, the balance may be met with eligible donations and grants to blended-finance instruments, with grants counted at twice their value.

Yes — colloquially. The "Singapore family office tax incentive" usually refers to one of these two schemes. The formal regimes are administered by MAS (with IRAS providing the tax exemption). Section 13D is a separate, self-assessed exemption for non-resident funds that needs no MAS approval. The former sections 13CA, 13R and 13X were renumbered 13D, 13O and 13U in the Income Tax Act 1947, 2020 Revised Edition (in force 31 December 2021).

Both schemes require the fund to invest at least the lower of 10% of AUM or S$10 million in 3 options: Listed on MAS-approved exchanges; Distributed by MAS-licensed financial institutions in Singapore (excluding equities listed outside approved exchanges); Non-listed Singapore-incorporated companies with operating businesses and substantive presence in Singapore. Certain categories count at twice their value, including equities listed on MAS-approved exchanges and non-listed Singapore operating companies with substantive presence in Singapore. The condition is first tested at the end of the first full financial year after the award starts, then every year-end.

Processing time is not set out in the MAS circular, and MAS may ask for further information during review. A pre-application engagement with MAS via your appointed Singapore counsel is recommended before formal submission; confirm current timelines with your adviser.

No, but you need substance. 13O and 13U both require qualifying investment professionals who are Singapore tax residents and engaged substantially in fund management. The family principal can remain in their home country while the Singapore-resident investment team carries the substance burden.

The minimum AUM (S$20 million for 13O, S$50 million for 13U) is tested at application and at the end of each financial year. A fund that fails any economic condition in a financial year cannot claim the tax exemption for that year; if it meets all the conditions again in a later year, it can claim the exemption for that later year. Separately, failing to employ the full investment-professional team by the end of the award's first financial year revokes the award from its start date.

Cryptocurrency and digital-asset investment income is treated case-by-case under "specified investment income" rules. MAS has not provided blanket guidance. Family offices with material digital-asset exposure should engage Singapore tax counsel for a private ruling. Custody of digital assets via licensed SG custodians (e.g. Standard Chartered Zodia, OKLink SG) is the typical regulatory wrapper.

Section 13O / 13U schemes are designed for fund-vehicle structures (typically VCC or Singapore Pte Ltd). A trust holding investments must channel the investment activity through a fund-vehicle sub-structure to benefit from the exemptions. Standalone trusts do not qualify directly.