Singapore VCC insights

Hong Kong or Singapore Fund Manager? Licensing, Talent, Vehicles and Carry Compared

By VCC Editorial Team · Published 18 October 2026

Short answer: Neither hub wins outright. Hong Kong suits a North Asia or Greater China hedge fund that serves professional investors only and can use its existing carried interest concession. Singapore suits Southeast Asia and India private markets, venture capital and teams that want the VCC. Hong Kong’s 2026 carry Bill is still not law.

This article is general information only and is not legal, tax or investment advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

Choosing between Hong Kong and Singapore as a fund manager’s base comes down to four tests: who licenses you, how quickly your team can move, which vehicle your investors expect, and how your carry is taxed. This guide covers a manager relocating its regional investment team, not a family office. All sources were checked on 18 October 2026 on the regulators’ and legislatures’ own sites, and statements about what is in force are as at that date.

Hong Kong or Singapore fund manager: what actually decides the location?

Four factors decide it: where your portfolio managers will live, where your investors and deal flow sit, which vehicle your limited partners already understand, and whether your carry qualifies for a concession. Headline tax rates matter less than people expect, because both are already low.

Hong Kong profits tax for corporations is 16.5%, with 8.25% on the first HK$2 million, and salaries tax at the standard rate is 15% on the first HK$5 million of net income and 16% above that from 2024/25. Singapore’s corporate rate is a flat 17%, and the top resident personal rate is 24% above S$1 million from Year of Assessment 2024. For a senior portfolio manager, the treatment of carried interest usually matters more.

How does SFC Type 9 licensing compare with an MAS CMS licence?

Both regimes are activity-based and both require local supervision. Hong Kong licenses the firm for Type 9 and approves responsible officers individually; Singapore licenses the firm as a licensed fund management company (LFMC) and appoints key staff as representatives.

The Securities and Futures Commission (SFC) hedge fund manager guide says Type 9 is generally needed to manage securities or futures portfolios on a discretionary basis, and that the SFC usually imposes conditions that the firm will not hold client assets and will serve professional investors only. Under the SFC Licensing Handbook (July 2025), a firm needs at least two responsible officers per regulated activity, one available at all times and at least one an executive director. Some may be based offshore if they can supervise effectively.

In Singapore, s 82 of the Securities and Futures Act 2001 prohibits carrying on a regulated activity without a CMS licence, subject to the Third Schedule and s 99 exemptions. MAS assesses the business model, controls, track record, fitness and propriety and minimum financial requirements, and expects a dedicated, secure office. Managers running only venture capital funds can use the simpler venture capital fund manager (VCFM) regime. See our guides to the LFMC application file and the exemptions after the RFMC repeal.

Point	Hong Kong (SFC Type 9)	Singapore (MAS CMS licence, LFMC)
Legal basis	Securities and Futures Ordinance (Cap. 571), Schedule 5	Securities and Futures Act 2001, s 82 and Second Schedule
Key individuals	At least two responsible officers per activity; at least one an executive director; all executive directors approved as responsible officers	Representatives for portfolio management, research, marketing and client servicing; fit and proper review of shareholders and directors
Capital, no client assets	No paid-up minimum; HK$100,000 liquid capital; half-yearly financial returns	Minimum financial requirements prescribed under the SFA, by LFMC category
Capital, other cases	HK$5,000,000 paid-up; HK$3,000,000 liquid capital	As above
Stated processing time	About 15 weeks (corporation); 10 weeks (responsible officer)	Up to 6 months for a complete file; up to 6 months more to meet in-principle approval conditions
Annual fee noted by regulator	Not compared here	S$4,000 corporate fee for an LFMC
Venture capital route	None specific	VCFM regime

Two further points help senior teams. The SFC may exempt individuals with at least eight years’ relevant experience who serve only professional investors from the local regulatory exam, if they complete five extra training hours within 12 months. MAS says it received more than 500 fund management licence applications over three years, with the quickest approved in 12 weeks.

Which hub makes it easier to relocate the investment team?

For someone without a signed contract, Hong Kong is easier today, because TTPS needs no job offer. Singapore’s routes depend on a Singapore employer except the ONE Pass, and its Investment Management Track for performance-paid managers opens only in late January 2027.

Under TTPS, Category A (annual income of HK$2.5 million or more in the preceding year) gives a 36-month stay with no other conditions; Categories B and C, for graduates of listed universities, give 24 months. The General Employment Policy (GEP) needs a confirmed job offer and market pay, normally takes four weeks and gives an initial 36 months. After two years, a professional with assessable income of at least HK$2 million can move to the five-year top-tier stream.

In Singapore, the Ministry of Manpower (MOM) Employment Pass qualifying salary for financial services is S$6,200 a month, rising with age to S$11,800 at 45 and above, and S$6,600 to S$12,700 for new applications from 1 January 2027. Candidates must also score 40 points under COMPASS unless their fixed monthly salary is at least S$22,500. The ONE Pass needs S$30,000 fixed monthly salary for the past 12 months from an established company (market capitalisation of at least US$500 million or revenue of at least US$200 million) and is renewable for five years at a time.

In his 29 September 2026 speech, MAS Deputy Chairman Chee Hong Tat said the Investment Management Track would let applicants meet S$30,000 with at least S$15,000 fixed salary plus variable pay, sustained over the past three years. MOM’s ONE Pass page (last updated 14 September 2026) does not yet list it, so treat it as announced, not in force. See our ONE Pass guide. Mr Chee also said eligible founders, equity partners and senior decision makers of global asset managers can seek permanent residence under the Global Investor Programme. Our sister firm Singapore Employment Agency handles pass filings.

Which fund vehicle fits: OFC and LPF or VCC and LP?

Each hub has a corporate fund and a partnership fund, and each corporate vehicle must be run by a locally licensed or registered manager, so the vehicle follows the manager.

A Hong Kong open-ended fund company (OFC) needs at least two individual directors, one independent, an investment manager licensed or registered for Type 9, and an eligible custodian. The SFC grant scheme for OFCs accepts applications until 9 May 2027 for eligible set-up or re-domiciliation costs paid to Hong Kong providers. A limited partnership fund (LPF) is registered under the Limited Partnership Fund Ordinance (Cap. 637) and must be audited annually.

In Singapore, s 46 of the Variable Capital Companies Act 2018 requires a VCC to have a manager at all times: a CMS licensee for fund management, a person under s 99(1)(a) to (d) of the Securities and Futures Act 2001, or a prescribed person. A VCC cannot manage itself; one category was deleted with effect from 6 May 2026. Partnerships use the Limited Partnerships Act 2008. We compare the private equity case in VCC vs Hong Kong LPF.

How is carried interest taxed in Hong Kong today, and what would the 2026 Bill change?

Hong Kong’s concession is in force but narrow: it relies on HKMA fund certification and was built for private equity. The 2026 Bill would widen it substantially, but it was not law on 18 October 2026.

The Inland Revenue (Amendment) (Tax Concessions for Carried Interest) Ordinance 2021 (Ord. No. 9 of 2021) came into operation in May 2021. The Inland Revenue Department (IRD) lists a 0% rate for “net eligible carried interest derived by a qualifying person under specified conditions” from 2020/21, and the IRD FAQ says the salaries tax exclusion is “at present” 100%. A qualifying employee must be employed by a qualifying person or its associated entity in Hong Kong and provide investment management services in Hong Kong; seconded staff without a local contract do not qualify. The employer must file Form IR6177 or the employee’s claim cannot be considered.

According to the LegCo Legal Service Division report (LS35/2026), the Inland Revenue (Amendment) (Preferential Tax Regimes for Funds, Family-owned Investment Holding Vehicles and Carried Interest) Bill 2026 would:

• remove the HKMA certification requirement;
• widen “associate” for qualifying payers;
• drop the hurdle-rate reference from eligible carried interest; and
• extend eligible sources of profit beyond private equity transactions, including a fund’s other taxable profits.

On 12 August 2026 the Financial Services and the Treasury Bureau (FSTB) said proprietary trading businesses are not “funds” and do not benefit, that clause-by-clause examination was complete, and that the Government “does not have plans to further expand the scope” of the measures. LegCo’s bill page on 18 October 2026 shows gazettal on 12 June 2026, first reading on 24 June 2026 and Bills Committee consideration from 8 July 2026, with second and third reading, passage and Ordinance gazettal blank. If passed, it applies to years of assessment from 1 April 2025, and the IRD allows eligible taxpayers to file 2025/26 returns on the Bill’s basis, subject to later revision.

What is Singapore’s position on carried interest?

Singapore has announced an exemption but not legislated it. In its 19 August 2026 media release, MAS said it and the Ministry of Finance “plan to introduce” an exemption for profit-related returns from fund management services to qualifying funds, expected from Year of Assessment 2027, where a share of fund profits is contractually received by companies, partnerships or individuals. Mr Chee later said it would cover income earned in the 2026 basis period. Scheme design, qualifying funds and anti-avoidance rules await Budget 2027.

So Hong Kong has an enacted but narrow concession and Singapore an announced but undefined one. Model both on current law and on proposals enacted, and do not sign a lease on either proposal alone.

Which hub suits which strategy?

Strategy is a better guide than tax. The table is our view of where current rules fit best, not a ranking.

Strategy	Tends to favour	Why
Greater China or North Asia long/short hedge fund, professional investors only	Hong Kong	Light Type 9 capital with a no-client-assets condition; TTPS lets the team move first. The current carry concession is aimed at private equity.
Southeast Asia or India private equity and growth equity	Singapore	VCC or limited partnership under a Singapore LFMC; the proposed exemption targets funds managed from Singapore.
Venture capital	Singapore	VCFM regime with simpler admission criteria.
Private credit	Depends on pipeline	Hong Kong’s pending Bill would add loans and private credit to qualifying investments.
Global multi-strategy platform	Often both	Licensed entities in each hub, with vehicles following the lead portfolio managers.

The family office angle differs, because a single family office managing its own money often needs no licence in either hub; see Family Office Singapore vs Hong Kong.

What is a sensible sequence for a relocating manager?

People first, then licence, then vehicle, then carry. The reverse order tends to produce structures that fail substance tests.

1. Map where each portfolio manager and responsible officer or representative will live and decide for the next three years.
2. Test each person against the immigration route (TTPS or GEP; Employment Pass, ONE Pass or, from late January 2027, the Investment Management Track).
3. Fix the licence perimeter: Type 9 with or without client assets, or LFMC versus VCFM, and budget about 15 weeks (SFC) or up to 6 months plus in-principle approval (MAS).
4. Choose the vehicle matching the licensed manager: OFC or LPF in Hong Kong, VCC or limited partnership in Singapore.
5. Model carry under current law and enacted proposals; track the Hong Kong Bill and Singapore’s Budget 2027.
6. Document substance: local employment contracts for carry recipients, investment management agreements and minutes showing where decisions are made.

Frequently asked questions

Has Hong Kong’s 2026 carried interest Bill been passed?

No. As at 18 October 2026, LegCo’s bill page shows no second or third reading, passage date or gazetted Ordinance. If passed, it would apply from 2025/26.

Can a Singapore-licensed manager run a Hong Kong OFC?

Not directly. The SFC requires an OFC’s investment manager to be licensed or registered for Type 9, so a Hong Kong licensed entity would be needed in that role.

Is Singapore’s carried interest exemption in force?

No. It was announced on 19 August 2026 as a plan expected from Year of Assessment 2027, with details due at Budget 2027.

Which is faster to license, Hong Kong or Singapore?

The SFC estimates about 15 weeks for a licensed corporation. MAS says up to 6 months for a complete file and reported a median of four and a half months in 2Q 2026. File quality and team experience drive both.

Sources

• SFC Licensing Handbook (July 2025)
• IRD: FAQ on salaries tax concessions for eligible carried interest
• IRD press release: FSTB responds to media enquiries on carried interest (12 August 2026)
• MAS media release (19 August 2026)
• MAS: Fund Management Licensing

Raffles Corporate Services helps fund managers relocating to Singapore with LFMC preparation, VCC incorporation, work pass coordination and ongoing compliance. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 18 October 2026. The Editorial Team, Variable Capital Companies Act.