Singapore VCC insights

Family Office Cost per Year: The Regulatory Floor in Singapore, Hong Kong and Dubai

By VCC Editorial Team · Published 27 October 2026

Short answer: No regulator publishes a running cost; each hub fixes only a floor. Singapore’s 13O and 13U schemes require two or three qualifying investment professionals and S$200,000 or more of local spending. Hong Kong’s concession requires two full-time staff and HK$2 million of expenditure. DIFC charges USD 12,000 for the licence but sets no staffing minimum.

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.

Quoted ranges for running a family office rarely trace to any source. This guide works from the inputs each regime makes compulsory (staff, local spending, official fees and recurring filings), which form the regulatory floor beneath any realistic family office cost per year in Singapore, Hong Kong and the Dubai International Financial Centre (DIFC). Costs above the floor are the family’s choice, so we list them as drivers without invented numbers. Every regulatory figure was checked against official publications on 27 October 2026.

What sets the family office cost per year in each hub?

Three layers make up the cost, and only two are fixed by law: the substance floor (compulsory headcount and spending) attached to a tax concession, and official fees and filings. The third layer, covering pay above the minimum, premises, custody and advice, is discretionary.

The point most budgets miss is that in Singapore and Hong Kong the substance floor binds only if the family wants the tax concession. The conditions of Singapore’s SFO licensing exemption, as listed in the MAS FAQs of 12 June 2026, cover whose money is managed, Singapore incorporation and bank accounts, not headcount. The IP and spending conditions come from the 13O and 13U fund schemes. In Hong Kong, the two-employee and HK$2 million tests are conditions of the FIHV profits tax concession, which a vehicle opts into by irrevocable written election. A family that does not need the concession is not held to these floors, though its tax bill may then be higher.

How many staff does each regime require?

Singapore requires 2 or 3 qualifying IPs for a 13O or 13U fund. Hong Kong requires at least 2 qualified full-time employees in Hong Kong for an FIHV. The DIFC Family Arrangements Regulations contain no headcount requirement.

Requirement	Singapore (13O / 13U SFO fund)	Hong Kong (FIHV concession)	DIFC (Family Office Licence)
Minimum professional headcount	13O: 2 qualifying IPs. 13U: 3 qualifying IPs. In both, at least 1 must be a non-family member	At least 2 full-time employees in Hong Kong with the necessary qualifications	None set by the Regulations
Who counts	Portfolio managers, research analysts and traders who are Singapore tax residents, earn more than S$3,500 a month and spend more than 50% of their time on fund management	Staff carrying out the core income generating activities. These may be outsourced to the eligible SFO, provided the outsourcing is not used to get around the requirement	Not applicable
Ramp-up allowance	Apply with one fewer IP (13O: 1; 13U: 2). The full complement must be in place by the end of the basis period of the first year of assessment (YA), or the award is revoked from its start date	None stated. The test applies for each basis period	Not applicable
Proportionality	Fixed minimum	Must be “commensurate” with the level of activity. The Inland Revenue Department (IRD) “will not apply a mechanical multiplication or division exercise”	Not applicable

Two budgeting points follow. In Singapore, the final hire falls in the first financial year: MAS’s example is an award starting 1 August 2026 with a 31 December year end, which needs the second IP by 31 December 2026. In Hong Kong, the figures are minimums, not safe harbours; a larger portfolio may need more people. Our line-by-line comparison of the FIHV and 13O tests covers the eligibility side. Hiring foreign IPs in Singapore also brings work pass costs; see our guide to Employment Passes for 13O and 13U professionals and, for pass applications, Singapore Employment Agency.

Is there a minimum amount the family office must spend?

Yes in Singapore and Hong Kong, but only as a condition of the tax concession. DIFC has none. Singapore’s floor is tiered by AUM. Hong Kong’s is a flat HK$2 million of operating expenditure in Hong Kong.

In Singapore, MAS FDD Circular 05/2026 (see the MAS family office schemes page; Table C, paragraph 4.5(a)) sets a minimum local spending condition for 13O and 13U SFO funds approved on or after 1 August 2026. It is S$200,000 where AUM in designated investments is below S$250 million, S$500,000 from S$250 million to below S$2 billion, and S$1,000,000 at S$2 billion and above. In the two upper tiers, eligible donations and grants to blended finance instruments can count, subject to a minimum of S$300,000 or S$500,000 of local business spending. Our 13O vs 13U decision guide explains the tiers and which scheme suits which family.

Annex 6B to the circular defines local business spending as operating expenses “including but not limited to remuneration, fund management fees and other operating costs” paid to contracting parties in Singapore. So the compulsory IPs’ salaries count towards the floor rather than sitting on top of it. Two IPs paid just over S$3,500 a month cost a little over S$84,000 a year (our arithmetic; real salaries are commercial), so below S$250 million of AUM the rest of the S$200,000 must come from other Singapore-paid costs or higher pay.

In Hong Kong, the HK$2 million must be operating expenditure incurred in Hong Kong for the investment activities, by the FIHV or by the eligible SFO on its behalf, and commensurate with the activity.

DIFC turns on wealth, not spending: a Minimum Net Asset Requirement of USD 50 million (fair market value, or book value where that cannot be ascertained), confirmed annually. That is a qualification test, not a cost.

What official fees does each hub charge?

The official fees are small next to staff costs. Their structure differs, though: Singapore and Hong Kong charge ordinary company fees, while DIFC adds a family office licence fee.

Fee	Singapore	Hong Kong	DIFC
Company set-up	ACRA: S$15 name application plus S$300 registration	Companies Registry: HK$1,545 (electronic) or HK$1,720 (hard copy)	Registered Person fees under the Registrar of Companies table of fees (not reproduced here)
Family office regime fee	MAS SFO Notification: the MAS FAQs describe an online filing and an acknowledgement. They mention no fee	No licence fee in the FIHV regime; the concession is claimed by written election	Family Office Licence: USD 12,000 (Appendix 2)
Annual company filing	ACRA annual return: S$60	Annual return: HK$105 if delivered within 42 days after the return date, rising to HK$3,480 if more than 9 months late	Annual Confirmation Statement (Regulation 7.5.1); any annual Registered Person fees per the Registrar’s fee table
Business registration	Not applicable	One-year certificate commencing 1 April 2026 to 31 March 2027: HK$2,200 fee plus HK$150 levy (HK$2,350)	Not applicable
Privacy option	Not applicable	Not applicable	Private Register entry or removal: USD 1,000

In DIFC, Regulation 8 makes the Appendix 2 fees payable “in addition to any applicable fees payable by it to the Registrar as a Registered Person”, so add the general company fees from the Registrar’s current table. Regulation 7.4 also lets a family office with a substantial UAE presence use its corporate service provider’s DIFC address as its registered office, which can change the premises line.

Which recurring filings and audits generate professional fees?

Recurring filings, not government fees, drive the annual professional spend. Each hub needs a tax return backed by financial statements, an annual corporate filing, and family office confirmations.

• Singapore: an SFO annual return to MAS within four months of financial year end (no further extension), an ACRA annual return, a corporate income tax return due 30 November (an exempt 13O or 13U fund should expect Form C, since Form C-S is limited to income taxable at 17%), and the reporting under the award letter.
• Hong Kong: a Profits Tax Return submitted “together with the audited financial statements” (the IRD waives them only for companies dormant under section 5 of the Companies Ordinance (Cap. 622)), a Companies Registry annual return, business registration renewal and FIHV beneficial ownership records.
• DIFC and UAE: an annual Confirmation Statement with the Regulation 7.5.1(c) confirmations (family members served, services provided, the USD 50 million requirement), source of wealth and funds records kept for six years (Regulation 7.1), and a corporate tax return within 9 months of each tax period. Under Ministerial Decision No. 84 of 2025, audited financial statements are compulsory for a Qualifying Free Zone Person and for a taxable person (not a tax group) with revenue above AED 50 million, for tax periods from 1 January 2025.

How does tax on the family office itself change the annual cost?

The management company is usually taxed on its service income even when the investment vehicle is exempt, so tax on its margin is a recurring cost in every hub.

In Singapore, the 13O or 13U exemption applies to the fund vehicle, not to the SFO company that manages it. Unless another incentive applies, the SFO’s fee income is taxable at the corporate rate of 17%. In Hong Kong, profits tax for corporations is 8.25% on the first HK$2 million of assessable profits and 16.5% on the rest. An eligible SFO must derive at least 75% of its assessable profits from services to specified persons of the family, and those fees must be chargeable to tax. An FIHV’s qualifying profits are taxed at 0%. In the UAE, corporate tax is 0% on taxable income up to AED 375,000 and 9% above it. A Free Zone Person that meets the conditions of a Qualifying Free Zone Person pays 0% on qualifying income.

Hong Kong’s Inland Revenue (Amendment) (Preferential Tax Regimes for Funds, Family-owned Investment Holding Vehicles and Carried Interest) Bill 2026 was gazetted on 12 June 2026 and remains before the Legislative Council. On 27 October 2026, the IRD’s “What’s New” page carried no notice of its passage. We found no official statement that the Bill changes the two-employee or HK$2 million substance minimums.

How do you build a family office budget per year from these inputs?

Start from the floor the chosen regime imposes, then add discretionary costs on top. Number and figure only what you can source.

1. Decide whether you need the concession (13O, 13U or FIHV). Without it the floors fall away, but price the extra tax.
2. Fix the compulsory headcount, scaled up if the portfolio requires it.
3. Test locally paid costs against the spending floor for your hub and AUM.
4. Add the official fees above, including DIFC Registered Person fees if relevant.
5. Add audit, tax return, annual return and family office confirmation.
6. Add discretionary drivers last, each priced from a written quote.

The template below lists the drivers without figures. Fill in your own quotes. Our quote-backed annual budget method shows how to normalise provider proposals and keep the evidence file.

Cost driver	Fixed by regulation?	Your figure (Singapore)	Your figure (Hong Kong)	Your figure (DIFC)
Compulsory investment staff	Count fixed in Singapore and Hong Kong (if concession sought); pay is commercial
Other staff (operations, finance, compliance)	No
Premises	No (DIFC registered office may be the corporate service provider’s under Regulation 7.4)
Official registration and licence fees	Yes (see fee table)
Audit and tax return	Obligation fixed; price commercial
Corporate secretarial and annual filings	Obligation fixed; price commercial
Fund administration, custody, banking	No (a bank account is a condition in Singapore)
Legal, tax and structuring advice	No
Tax on the office’s own profit	Rate fixed by law

Which hub has the lowest compulsory cost?

On compulsory inputs alone, DIFC has the lightest floor: a licence fee and annual confirmations, with no headcount or spending condition. That does not make it the cheapest place to run a real investment operation, because a family that employs investment staff anyway largely absorbs the Singapore and Hong Kong floors.

For a family that will employ investment professionals whatever happens, the real differences come from salaries, rent and tax on the office’s margin, and no official source prices those. Our Singapore vs Dubai family office comparison covers regulation, residency and resilience, which should weigh as heavily as cost.

Frequently asked questions

Does MAS charge a fee to notify it of a single family office?

The MAS FAQs on the licensing exemption framework (issued 12 June 2026) describe an online Notification filed within 14 days of starting operations, with a system-generated acknowledgement. They mention no fee. Existing SFOs have until 15 June 2027 to comply and notify.

Do the salaries of the required investment professionals count towards Singapore’s local spending floor?

Yes, if they are paid in Singapore. Annex 6B to MAS FDD Circular 05/2026 defines local business spending to include remuneration paid to contracting parties in Singapore.

Is the DIFC USD 12,000 fee charged every year?

Appendix 2 of the Family Arrangements Regulations lists USD 12,000 against the Family Office Licence application. It does not state a separate annual amount. Any annual fees payable as a Registered Person are set by the DIFC Registrar’s fee schedule, so check the current table before you budget.

What happens in Singapore if the second investment professional is hired late?

Under paragraph 4.3(a) of the circular, if the SFO does not employ the required number by the end of the basis period of the first YA, the award is revoked with effect from its commencement date.

Sources

• MAS FDD Circular 05/2026, Tax Incentive Schemes for Funds (31 July 2026)
• Inland Revenue Department: Tax Concessions for Family-owned Investment Holding Vehicles
• DIFC Family Arrangements Regulations 2023
• ACRA: Service and transaction fees for companies
• Hong Kong Companies Registry: Major fees under the Companies Ordinance

Raffles Corporate Services helps families work out what a family office will cost to run before they commit to a hub, and handles VCC incorporation, family office set-up and ongoing compliance in Singapore. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 27 October 2026. The Editorial Team, Variable Capital Companies Act.