Singapore VCC insights

Australians Moving Wealth to Singapore: Leaving Australia, the 2026 Tax Changes and Where to Land

By VCC Editorial Team · Published 9 November 2026

Short answer: Australians moving wealth to Singapore meet a departure CGT charge first: ceasing Australian residence deems most non-property assets sold at market value unless the person chooses to disregard gains. The 2026 CGT and trust changes raise the cost of delay. Singapore then taxes no capital gains on most investments and exempts foreign income received by residents.

For Australians moving wealth to Singapore, the order of events matters more than the destination structure. Australia’s 12 May 2026 Budget replaced the 50 per cent capital gains discount with indexation from 1 July 2027 and announced a minimum tax on discretionary trusts from 1 July 2028, and that has pushed family principals to ask whether to leave before or after those dates. This article sets out the Australian departure rules, the status of each 2026 measure at 9 November 2026, and what a Singapore landing structure can and cannot do. Australian points below come from government pages, including the ATO guidance on changing residency, not from commentary.

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

Which Australian rules decide when a family has left?

Australian tax residence is a question of fact tested against four statutory tests, and ceasing to be resident is the event that triggers the departure charge. The ATO lists the resides test, the domicile test, the 183-day test and the Commonwealth superannuation test.

The resides test is the primary test. The ATO says a person who goes overseas temporarily without setting up a permanent home in another country generally remains an Australian resident for tax purposes. The domicile test makes a person resident if their domicile is in Australia, unless the Commissioner is satisfied that their permanent place of abode is outside Australia. A principal on a Singapore pass who keeps the Melbourne home and school places should not assume residence has ended.

The ATO also notes that a person who is a dual resident, resident of Australia under domestic law and of another country under that country’s law, is usually sorted by a treaty tie-breaker where Australia has a double tax treaty with the other country. Singapore and Australia have such a treaty, and its text is published by IRAS. Keep dated evidence of where the household actually lives. Our comparison of six home-country departure taxes shows how Australia’s approach differs from other jurisdictions.

What does Australia charge when a resident leaves?

Australia treats the departure as a deemed sale of most assets at market value on the day residence ends. The ATO says that on ceasing to be an Australian resident a person is taken to have disposed of CGT assets for their market value, except any taxable Australian property.

Taxable Australian property is, broadly, real estate in Australia and assets used in an Australian business. Foreign and temporary residents are taxed on capital gains only on that property, which is why it is left out of the deemed sale. The ATO example is a couple whose listed shares are deemed sold at departure while their rented Australian apartment is taxed only when sold.

Asset held at departure	Treatment on ceasing Australian residence (ATO guidance)
Listed shares and managed fund units (not taxable Australian property)	Deemed disposal at market value on the departure date, with the full 50 per cent discount available if the person was always Australian resident while owning the asset; or choose to disregard all gains and losses
Australian real estate and Australian business assets (taxable Australian property)	No deemed disposal; taxed when sold, with an apportioned discount for the period of Australian residence for assets acquired after 8 May 2012
Indirect Australian real property interests, and options or rights to acquire them	Taken to be immediately re-acquired at market value
A trust that stops being a resident trust for CGT purposes	Same deemed disposal rule applies

The choice to disregard is the main alternative. An individual can choose to disregard all capital gains and losses on leaving; the assets are then taken to be taxable Australian property until the earlier of a CGT event happening to them or the person becoming an Australian resident again. It is a choice over all gains and losses, so a principal cannot defer the gain on one holding while crystallising a loss on another. It defers the Australian tax rather than removing it.

How do the 2026 CGT and trust changes affect the timing of a move?

They change what a later Australian gain looks like more than they change the departure rule itself. The Treasury material read for this review does not address how the new regime interacts with a change of residence, so that point should go to an Australian tax adviser before a departure date is fixed.

The record as at 9 November 2026 is set out below. The Parliament of Australia’s page for the Tax Reform No. 3 Bill is the source for legislative status.

Measure	Date or start	Status as at 9 November 2026
CGT discount replaced by indexation and a 30 per cent minimum tax on gains	Gains accruing on and after 1 July 2027	Law: Act No. 49 of 2026, passed both Houses on 25 June 2026, assented 26 June 2026
Gains accruing before 1 July 2027	Keep the 50 per cent discount	Stated in the Treasurer’s second reading speech of 28 May 2026
Rollover relief for restructuring out of a discretionary trust	Three years from 1 July 2027	In the Tax Reform No. 3 Bill 2026, not yet law
30 per cent minimum tax on discretionary trusts	1 July 2028	Tax Reform No. 3 Bill 2026 introduced 14 October 2026, passed the House 29 October 2026, Senate committee report due 13 November 2026
Division 296 tax on large super balances	1 July 2026	Described by the ATO as law

The trust measure is built around the trustee. According to the Treasurer’s second reading speech of 14 October 2026, trustees would pay the minimum tax on the taxable income of a discretionary trust, and beneficiaries other than corporate beneficiaries would receive non-refundable offsets for the tax the trustee pays. Fixed trusts, charitable trusts, special disability trusts, superannuation funds, deceased estates and genuine testamentary trusts are excluded, as is primary production income. A trust can also elect to avoid the tax by distributing to pre-nominated beneficiaries under an up-front nomination.

For a family holding wealth in a discretionary trust, the live questions are whether to restructure within the three-year rollover window and whether the election suits its distribution pattern. The material reviewed does not say how the tax treats a departing beneficiary, so that is an open point for Australian advisers.

What about superannuation when an Australian family relocates?

Superannuation sits outside the departure CGT analysis, and the 2026 change that matters is Division 296. The ATO states that from 1 July 2026 an additional 15 per cent tax applies to the proportion of earnings relating to a total super balance above the A$3 million large super balance threshold, and a further 10 per cent above the A$10 million very large threshold, both indexed to CPI.

The ATO pages read for this review do not say how Division 296 applies to a person who has left Australia, so this article does not either. A principal with a large balance should take Australian advice before departure.

What changes for Australians moving wealth to Singapore after arrival?

Singapore taxes a resident individual on income earned in Singapore and exempts most foreign income brought in. IRAS states that a tax resident’s foreign-sourced income, with the exception of income received through partnerships in Singapore, is tax-exempt when brought into Singapore, and that resident rates run progressively from 0 per cent to 24 per cent.

Residence is tested differently from Australia. A foreigner is a tax resident for a year of assessment if they stayed or worked in Singapore for at least 183 days in the previous calendar year, or continuously for three consecutive years. IRAS also applies a two-year concession for employees whose employment straddles two calendar years and covers at least 183 days in total, but it excludes company directors. Foreigners issued with a work pass valid for at least one year are treated as residents, subject to review when they cease employment.

Singapore does not tax most capital gains for individuals. IRAS says gains from selling shares and other financial instruments are generally viewed as personal investments and are not taxable, while gains from property can be taxed where the person is trading in property, judged by frequency, reasons for buying and selling, financial means to hold long term and holding period. Our guide to Singapore tax residence for family office principals covers foreign income, gains and section 10L in more detail.

Which Singapore structure suits an Australian family office?

The structure follows the assets and the decision-making, not the other way round. A principal holding marketable securities personally may need no entity, while a pooled vehicle or incentive status needs a purpose-built one.

Route	What it needs	Fit for an Australian family
Personal holding after becoming Singapore resident	Singapore residence under the IRAS tests; foreign income exemption applies on remittance, other than through partnerships	Simple families with portfolio assets and no pooled vehicle
Single family office under the MAS licensing exemption framework	Notification to MAS, an account with a MAS-licensed bank and a yearly return; existing SFOs have until 15 June 2027 to comply	Families managing only their own wealth through an entity
Family office fund incentive, section 13O	S$20 million designated investments, 2 investment professionals, at least 1 not a family member	Mid-sized families wanting an incentive
Family office fund incentive, section 13U	S$50 million designated investments, 3 investment professionals, at least 1 not a family member	Larger families with a team in Singapore

The MAS family office page sets local spending minimums that scale with assets, from S$200,000 where designated investments are below S$250 million,. The MAS media release confirms that the revised single family office framework took effect on 15 June 2026. Our guide to 13O, 13U and VCC issues and our article on family office planning for tax residence compare these routes, and our two Australian vehicle comparisons, the managed scheme and the CCIV, cover the fund-level question.

In what order should an Australian family make the move?

Settle the Australian position first, then the Singapore status, then the structure. Reversing that order is the usual error, because an entity set up in Singapore does not change the date on which Australian residence ends.

1. Map the holdings: separate taxable Australian property from other assets, and list each trust, company and super fund.
2. Fix the departure facts: decide the date the household stops living in Australia, and document the resides test and domicile test position with a dated record.
3. Model both Australian paths: the deemed disposal at market value on departure against the choice to disregard, using the same valuation date and cost base records.
4. Review trusts and super with an Australian adviser: the trust rollover window from 1 July 2027, the election, and Division 296.
5. Secure Singapore status: the right pass for the principal and dependants, then track the 183-day and three-year residence tests. Our sister site explains Global Investor Programme options and pass sequencing for a family office.
6. Set up the structure only when the assets, people and spending needed for the chosen route are in place, and see the free tools for planning aids.

Frequently asked questions

Do Australians pay tax when they move to Singapore?

Leaving can trigger Australian CGT. On ceasing residence a person is taken to have sold most non-property assets at market value, unless they choose to disregard gains. Singapore does not tax capital gains on most investments, but taxes income arising in Singapore.

Is the new Australian capital gains regime already law?

Yes for the CGT change: Act No. 49 of 2026, assented on 26 June 2026. The discretionary trust minimum tax was still before the Senate on the record reviewed.

Can an Australian keep a trust after moving to Singapore?

The sources reviewed do not answer that for non-resident beneficiaries. A trust that stops being a resident trust for CGT purposes faces the same deemed disposal rule, and the new trust tax is designed around trustees. Take Australian advice on distributions before leaving.

Do Australians need a family office to move wealth to Singapore?

No. A resident individual can hold personal investments without an entity. A family office, section 13O or 13U fund, or VCC is relevant only where assets, staffing and the intended use justify it.

Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email hello@rafflescorporateservices.com. Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.

Last reviewed: 9 November 2026. The Editorial Team, Variable Capital Companies Act.