Singapore VCC insights
Singapore Single Family Office Tax Reforms: Which Condition Set Binds Your Award
Short answer: Under MAS FDD Cir 05/2026, an existing single family office fund’s rulebook depends on when it first applied to MAS: before 18 April 2022, from 18 April 2022 to before 5 July 2023, or from 5 July 2023. Each vintage has revised conditions in Annex 6B, starting with the first basis period ending on or after 1 August 2026.
Key facts at a glance
- Source: Monetary Authority of Singapore (MAS) circular FDD Cir 05/2026, “Tax Incentive Schemes for Funds”, 31 July 2026, paragraph 4.6 and Annexes 6B (sections 13O and 13OA) and 7B (section 13U) of the Income Tax Act 1947.
- Three existing-award vintages, pre-18Apr22, 18Apr22 and 5Jul23, are defined by the date of the fund’s preliminary submission, eligibility form or formal application (footnotes 32 to 34).
- Revised conditions apply from the Year of Assessment (YA) whose basis period ends on or after 1 August 2026: for a 31 December year end, the year ending 31 December 2026 (YA 2027).
- Pre-18Apr22: S$200,000 total business spending; no minimum assets under management (AUM), headcount or capital deployment row.
- 18Apr22: 2 investment professionals, tiered local spending and capital deployment; no minimum AUM row.
- 5Jul23: S$20 million AUM in designated investments at year end, 2 investment professionals (at least 1 non-family), tiered local spending and capital deployment.
- From 1 August 2026, Annex 13 standard terms override inconsistent terms in any letter of award (paragraph 8.2).
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.
The single family office tax reforms that MAS published on 31 July 2026 did not only set terms for new applicants. They re-wrote the annual conditions for every single family office (SFO) fund already holding a section 13O, 13OA or 13U award, by vintage. A fund approved in 2021 and one approved in 2024 now follow different rulebooks, and the deciding date is not always the one on the letter of award. This article sets the condition sets side by side, shows how to place an award, and works through a 2021, a 2022 and a 2024 example. Sources were checked on 26 October 2026 against the circular and MAS’s family office pages.
What did the single family office tax reforms change for existing awards?
They replaced the annual conditions in existing awards with a separate set that depends on vintage. Paragraph 4.6 of FDD Cir 05/2026 states that existing SFO awards subject to pre-18Apr22, 18Apr22 and 5Jul23 conditions “will be subject to a separate set of conditions with effect from the YA where the basis period ends on or after 1 August 2026, unless otherwise notified by MAS in writing”.
Three points follow. The change is keyed to a basis period, so different year ends produce different first years. MAS can vary the position for a particular fund in writing, so any such notice outranks the general table. And the detail sits in Annex 6B for 13O and 13OA awards and Annex 7B for 13U awards.
A second layer sits on top. Under paragraph 8.2, the Annex 13 standard terms apply from 1 August 2026 to new and existing awards and, where a pre-August 2026 letter differs, “will be in addition to, and to the extent of any inconsistency will supersede” it. Paragraph 2.4 is unchanged in principle: failing an economic condition costs the exemption for that basis period only, while failing a non-economic condition, such as not providing documents on request, can lead to permanent revocation.
Which condition set applies to your award?
The vintage turns on when the fund first submitted to MAS, not on when the award was approved. Footnotes 32 to 34 (repeated as Annex 6B footnotes 94 to 96) refer to “(i) a preliminary submission; (ii) an S13O/U Eligibility Form; or (iii) a formal application form”.
| Label used by MAS | Submission to MAS | Approval | Circular reference |
|---|---|---|---|
| Pre-18Apr22 conditions | Before 18 April 2022 | Before 1 August 2026 | Footnote 32; Annex 6B footnote 94 |
| 18Apr22 conditions | On or after 18 April 2022 but before 5 July 2023 | Before 1 August 2026 | Footnote 33; Annex 6B footnote 95 |
| 5Jul23 conditions | On or after 5 July 2023 | Before 1 August 2026 | Footnote 34; Annex 6B footnote 96 |
| New awards | Any date | On or after 1 August 2026 | Paragraphs 4.2 to 4.5; Annex 6B paragraphs 1 to 3 |
One labelling trap: Annex 6B paragraph 3 says awards approved on or after 1 August 2026 “can be referred to as ‘awards subject to 5Jul23 conditions'”, because their annual conditions are substantively similar to the revised 5Jul23 set. When a bank or adviser uses the “5Jul23” label, ask whether they mean an existing or a new award, since entry concessions and banking terms differ.
What does each condition set now require?
The revised annual conditions for 13O and 13OA SFO funds are in the Annex 6B paragraph 4 table; new awards are governed by Annex 6B paragraphs 1 to 3. “Not applicable” below reflects the circular’s “N/A” entries.
| Annual condition | Pre-18Apr22 | 18Apr22 | 5Jul23 | New award (approved on or after 1 August 2026) |
|---|---|---|---|---|
| Minimum AUM in designated investments | Not applicable | Not applicable (footnote 97) | S$20 million at end of basis period (para 1b) | S$20 million at application and end of each basis period (para 4.3(b)) |
| Investment professionals employed by the SFO | Not applicable | 2 throughout the basis period | 2, at least 1 non-family, throughout the basis period | 1 at application; 2, including 1 non-family, by end of first YA’s basis period (para 4.3(a)) |
| Minimum annual spending | Total business spending of S$200,000 | Tiered local spending (para 1c) | Tiered local spending (para 1c) | Tiered local spending (para 4.5(a)) |
| Capital deployment requirement | Not applicable | Para 1d | Para 1d | From first full YA (para 4.5(b)) |
| Banking account | Letter with private banking clause: continue to comply. Letter with no banking clause: banking or private banking account with an MAS-licensed financial institution, 3-month grace period from 1 August 2026 | Private banking account at application and throughout (para 4.5(c)) | ||
Tiered local spending (Annex 6B paragraph 1c) is identical in the 18Apr22, 5Jul23 and new-award columns. Below S$250 million of AUM in designated investments at year end, the fund needs S$200,000 of local business spending. From S$250 million to below S$2 billion, it needs S$500,000, at least S$300,000 of it local business spending. At S$2 billion or more, it needs S$1,000,000, at least S$500,000 of it local business spending. The balance can come from eligible donations to Singapore registered charities, exempt charities or Institutions of Public Character, and from grants to blended finance instruments distributed by licensed financial institutions in Singapore, counted at twice their value (footnotes 86 and 87).
The pre-18Apr22 test is different in kind: “total business spending” means operating expenses “regardless of contracting parties” (footnote 100), whereas local business spending counts only expenses paid to Singapore contracting parties (footnote 89).
Two rows have their own articles. Capital deployment (the lower of 10% of AUM in designated investments or S$10 million) is covered in our guide to the capital deployment requirement for 13O funds; the banking row and its grace period in SFO fund banking account condition.
How should you read your letter of award against the new rules?
Read it as one of three layers: the letter, the Annex 13 standard terms over it, and the Annex 6B column for the fund’s vintage. Where the letter conflicts with Annex 13, Annex 13 prevails; for annual economic conditions, the revised column applies from the first affected basis period.
- Record the award commencement date and financial year end; together they fix the first basis period ending on or after 1 August 2026.
- Pull the earliest submission date from your MAS correspondence and fix the vintage. The approval date does not decide it.
- Map each annual condition in the letter (AUM, headcount, spending, capital deployment) to the matching Annex 6B row, marking it unchanged, tightened, relaxed or new.
- Note whether the letter has a private banking clause, another banking clause or none.
- Check non-annual terms (reporting, notifications) against Annex 13, which can add to or replace them.
- File any written MAS notice that varies the position, since it overrides the table.
The result should be a one-page condition map, approved by the SFO’s board, that the administrator and auditor can test at year end. Our articles on the annual evidence file for 13O and 13U and the 13O annual compliance calendar cover the records and deadlines.
When does the new rulebook first apply to your fund?
From the YA whose basis period ends on or after 1 August 2026. The circular defines the basis period as “the financial year or period preceding the Year of Assessment” (footnote 9), so the first affected year depends on the year end.
| Financial year end | First basis period on revised terms | First YA affected |
|---|---|---|
| 31 December | 1 January 2026 to 31 December 2026 | YA 2027 |
| 31 March | 1 April 2026 to 31 March 2027 | YA 2028 |
| 30 June | 1 July 2026 to 30 June 2027 | YA 2028 |
| 31 August | 1 September 2025 to 31 August 2026 | YA 2027 |
This is our application of paragraph 4.6. A 31 December fund is already inside its first affected year, with about two months left to adjust headcount, spending and deployment; a 30 June fund has until 30 June 2027. Because most conditions are measured at or throughout the basis period, a gap found after year end usually costs that year’s exemption.
What changed for the 5Jul23 vintage?
The revised set is lighter on monitoring and spending. MAS’s earlier infographic on the 13O and 13U criteria for SFO funds, which set out the 5 July 2023 changes, described minimum AUM as applying “at the point of application and throughout the incentive period”, spending tiers stepping up at S$50 million and S$100 million of AUM, and a capital deployment list of six categories with 1.5x and 2x multipliers. The revised 5Jul23 column instead:
- tests S$20 million of AUM in designated investments at the end of the basis period (paragraph 1b);
- moves the spending tiers to S$250 million and S$2 billion (paragraph 1c), so a fund with S$150 million of AUM drops from the S$1 million tier to the S$200,000 tier;
- applies the three-option capital deployment test with a single 2x multiplier for specified categories (paragraph 1d).
The headcount rule is unchanged in substance. Qualifying professionals are portfolio managers, research analysts and traders who are Singapore tax residents, earn more than S$3,500 a month and engage substantially in fund management (footnote 82). For hiring routes, see our article on the Employment Pass for family office investment professionals or our sister site on Singapore work passes.
For the two older vintages the circular does not restate each fund’s original terms, which vary by letter, so the comparison must be made against the letter itself. It does record that 18Apr22 awards could take 2 years to grow from S$10 million to S$20 million of AUM (footnote 97) and 1 year to hire the second professional (footnote 98); the revised table now has no minimum AUM row for that vintage.
How do the condition sets play out for a 2021, 2022 and 2024 award?
These are illustrations with hypothetical facts. Each fund is a 13O company with no fund-specific notice from MAS.
2021 award: pre-18Apr22 conditions
Fund A applied in November 2021, was approved in March 2022 and has a 31 December year end. It submitted before 18 April 2022, so it sits in the pre-18Apr22 column despite its later approval. For its first affected basis period, calendar 2026 (YA 2027), it needs S$200,000 of total business spending, which can include fees paid to overseas providers, plus the banking condition matching its letter. There is no AUM, headcount or capital deployment row; the non-annual terms of its letter, read with Annex 13, still apply.
2022 award: 18Apr22 conditions
Fund B made its preliminary submission on 9 May 2022, was approved in December 2022 and has a 30 June year end. Its year ended 30 June 2026 stays on existing terms; the revised conditions start with 1 July 2026 to 30 June 2027 (YA 2028). The SFO must employ 2 qualifying professionals throughout. With S$180 million of AUM at 30 June 2027, it needs S$200,000 of local business spending, and its capital deployment requirement is the lower of S$18 million and S$10 million, so S$10 million. Had Fund B first submitted in March 2022, it would be a pre-18Apr22 fund with the same approval date.
2024 award: 5Jul23 conditions
Fund C applied in February 2024, was approved in September 2024 and has a 31 December year end; its first affected period is calendar 2026 (YA 2027). At 31 December 2026 it needs at least S$20 million of AUM in designated investments, excluding investment in the family’s operating businesses (footnote 84), and 2 qualifying professionals, including 1 non-family member, throughout 2026. With S$300 million of AUM it needs S$500,000 of spending, for example S$320,000 of local business spending, S$80,000 of eligible donations and S$50,000 of blended finance grants counted as S$100,000. On our reading, its S$10 million capital deployment requirement is tested at 31 December 2026.
What about funds with 13U awards?
The same vintages and start date apply, but the conditions sit in Annex 7B. For new 13U SFO awards, paragraph 4.4 sets 3 qualifying professionals (at least 1 non-family, with 2 permitted at application) and S$50 million of AUM in designated investments, and Annex 7 paragraph 3 applies the AUM and spending conditions at the level of the whole 13U structure. Annex 7B was not in the circular text we could extract for this review, so we do not reproduce its table; a 13U fund should read its Annex 7B column directly rather than assume the 13O figures carry across. Our guide to family office minimum AUM compares the 13O and 13U entry thresholds. For queries the Annex 11 and 12 FAQs do not answer, MAS’s family office page gives FO_13OU@mas.gov.sg.
Frequently asked questions
Does the approval date on my letter of award decide which conditions apply?
No. Each vintage is defined by the date of the fund’s preliminary submission, eligibility form or formal application. A fund approved after 18 April 2022 can still be a pre-18Apr22 fund.
Can my existing award keep its original conditions?
Only if MAS notifies the fund in writing. Paragraph 4.6 applies the separate set “unless otherwise notified by MAS in writing”, and Annex 13 overrides inconsistent letter terms from 1 August 2026.
My fund has a 31 December year end. Which year is first affected?
The year ending 31 December 2026, which is YA 2027.
Does a pre-18Apr22 award now need investment professionals?
The revised Annex 6B table shows “N/A” for headcount in that column. Non-annual conditions in the letter, read with Annex 13, still apply.
Sources
- MAS, FDD Cir 05/2026, “Tax Incentive Schemes for Funds”, 31 July 2026
- MAS, Fund Tax Schemes for Family Offices (last updated 22 September 2026)
- MAS, Section 13O and 13U Tax Incentives for Funds managed by Single Family Offices (infographic on the 5 July 2023 changes)
Raffles Corporate Services helps family offices map existing 13O and 13U awards to the revised MAS conditions, alongside VCC incorporation, family office set-up and ongoing compliance. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.
Last reviewed: 26 October 2026. The Editorial Team, Variable Capital Companies Act.