Skip to content
VARIABLE CAPITAL
COMPANIES ACT
Let’s talk

Singapore VCC insights

Family Office Philanthropy After the Finance (Income Taxes) Act 2026: Singapore’s 250% Extension and PTIS Against Hong Kong

Volunteers sorting donated canned food into boxes at a community food drive
Photo: Joel Muniz on Unsplash

Short answer: The Finance (Income Taxes) Act 2026 extends Singapore’s 250% deduction for qualifying gifts to IPCs and the Government to donations made up to 31 December 2029, in force from 4 November 2026. PTIS is unchanged: 100% for overseas gifts through approved intermediaries, capped at 40% of statutory income. Hong Kong still allows 100%, capped at 35%.

Family office philanthropy in Singapore has moved from a Bill to an enacted position. The Finance (Income Taxes) Bill (Bill No. 22/2026), which our earlier version of this article described as pending, was passed by Parliament on 6 October 2026, assented to on 29 October 2026 and is now the Finance (Income Taxes) Act 2026 (No. 23 of 2026). This update covers what the Act changed, what it left alone, and how the result compares with Hong Kong. Sources were checked on 8 November 2026 on Singapore Statutes Online (SSO), with the Inland Revenue Authority of Singapore (IRAS), the Monetary Authority of Singapore (MAS), the Charity Portal and Hong Kong’s Inland Revenue Department (IRD).

Key facts at a glance

  • Finance (Income Taxes) Act 2026 (No. 23 of 2026): passed 6 October 2026, assented 29 October 2026; section 17 (amending section 37 of the Income Tax Act 1947) commenced on 4 November 2026.
  • Section 37(3A)(a)(ii) now applies the 2.5 times multiplier to qualifying donations made from 1 January 2016 to 31 December 2029 (previously 31 December 2026).
  • PTIS: 100% deduction for overseas cash donations through Qualifying Local Intermediaries, for 5 years from an approved commencement date between 1 January 2024 and 31 December 2028, capped at 40% of the donor’s statutory income.
  • PTIS conditions: a philanthropy professional, an additional S$200,000 of local business spending and one additional local professional (MAS).
  • Unused deductions for local IPC gifts carry forward for up to 5 years; unused overseas (PTIS and humanitarian) deductions do not (IRAS).
  • Hong Kong: approved charitable donations deductible up to 35% of assessable income or profits, minimum HK$100 (Inland Revenue Ordinance, ss 16D and 26C).

What did the Finance (Income Taxes) Act 2026 change for family office philanthropy?

For family office philanthropy, the central change is the date: the 250% deduction for qualifying local donations now runs to 31 December 2029. A family that was planning around a 31 December 2026 cliff no longer needs to accelerate gifts into this calendar year to secure the multiplier.

Section 17 of the Finance (Income Taxes) Act 2026 amends section 37 of the Income Tax Act 1947 (ITA). Its main effects on giving are:

The SSO annotation on section 37 shows each of these as “wef 04/11/2026”.

Did the Act change the Philanthropy Tax Incentive Scheme?

Section 17 does not amend the Philanthropy Tax Incentive Scheme for Family Offices (PTIS), which is administered by MAS. The scheme’s terms on the MAS and IRAS pages checked on 8 November 2026 are the same as before the Act.

The IRAS page on donations and tax deductions (last updated 31 October 2026) states that approved Qualifying Donors receive a 100% deduction for overseas donations made through Qualifying Local Intermediaries (QLIs) for 5 years, starting from an approved incentive commencement date between 1 January 2024 and 31 December 2028, capped at 40% of the donor’s statutory income. MAS adds the qualifying conditions for the single family office (SFO) managing the section 13O, 13OA or 13U fund:

MAS lists eight approved QLIs as of 1 July 2026. Overseas gifts into blended finance, social impact bonds, impact investments or venture philanthropy can qualify only if the donor receives no principal repayment or returns.

The practical point is the 2028 end date for commencement. A family office that wants a full 5-year PTIS run must have its incentive approved with a commencement date no later than 31 December 2028; the 250% extension to 2029 does not move that date. The additional S$200,000 also sits on top of the fund scheme’s own spending tiers, discussed in our note on 13O and 13U local business spending.

How do Singapore’s donation deductions stack for one family?

Overseas deductions are used first and expire if unused; local IPC deductions are used last and can be carried forward. That ordering decides which gifts to make from which entity.

IRAS describes the sequence. PTIS deductions rank first. The Overseas Humanitarian Assistance Tax Deduction Scheme, a pilot giving 100% for cash gifts to approved overseas emergency causes through designated charities from 1 January 2025 to 31 December 2028, ranks behind PTIS but ahead of the 250% deductions. The two overseas schemes share one 40% cap on statutory income, and their unused deductions cannot be carried forward or transferred under group relief.

Local gifts behave differently. IRAS states that unutilised deductions for donations to approved IPCs for local causes may be carried forward for up to 5 years, so a gift made in 2026 (deducted in the year of assessment 2027) can be carried to 2032. Corporate donors must satisfy the shareholding test to use the carried-forward amount, and unutilised donations rank after trade losses and capital allowances. A family that restructures its holding company should check the shareholding test before assuming the carry-forward survives.

The deduction is given in the year of assessment following the gift, from the IPC’s records, so the donor must give its NRIC, FIN or UEN to the IPC; IRAS does not accept claims on receipts alone.

How does Hong Kong compare for a family office’s giving?

Hong Kong gives a single-rate deduction with a percentage ceiling. Singapore multiplies local gifts, adds a separate family office incentive for overseas giving, and lets unused local deductions roll forward.

According to the IRD guidance on charitable donations and tax-exempt charities, individual and business donors chargeable to salaries tax, personal assessment or profits tax may deduct approved charitable donations up to 35% of assessable income or profits, with an aggregate minimum of HK$100. An “approved charitable donation” is a donation of money to a charity exempt under section 88 of the Inland Revenue Ordinance (Cap. 112), or to the Government, for charitable purposes.

Point of comparison Singapore Hong Kong
Rate 2.5 times for qualifying local gifts to 31 December 2029; 100% under PTIS for overseas gifts 100% of approved charitable donations
Ceiling No percentage ceiling in s 37(3)(c); PTIS and the humanitarian scheme share a 40% cap 35% of assessable income or profits
Eligible recipient IPCs and the Singapore Government; overseas causes via PTIS QLIs or designated humanitarian charities Charities exempt under s 88 of the Inland Revenue Ordinance, or the Government
Form of gift Cash; listed shares and unit trust units (individuals only); land and buildings; approved artefacts and public art. PTIS covers cash only Money only
Family office incentive PTIS, tied to a 13O, 13OA or 13U fund None identified in the IRD material reviewed
Unused deductions Local IPC gifts: carry forward up to 5 years. Overseas schemes: lost Not addressed on the IRD page reviewed
Recognition of a family charity Charity registration, then IPC approval by the Commissioner of Charities Application on Form C.D.22; IRD aims to respond within 4 months of a complete application

Hong Kong also restricts a charity’s trading profits. The IRD states that such profits are exempt only if applied solely for charitable purposes, not expended substantially outside Hong Kong, and earned either in the course of carrying out the charity’s expressed objects or mainly by its beneficiaries.

For the investment side of the same comparison, see our line-by-line Hong Kong FIHV and Singapore 13O comparison.

Which entity in the structure should make the gift?

The donor should be the entity whose taxable income will absorb the deduction. A deduction set against income that is already exempt has little value.

That often points away from the 13O or 13U fund vehicle itself, where most of its income is exempt under the incentive, and towards the SFO company, an operating business in the family group, or a principal with taxable Singapore income. PTIS formalises this by letting the SFO nominate one donor from four categories.

Individual principals have one extra route. Section 37(3)(e) gives the 2.5 times deduction for listed shares and unit trust units donated by an individual, and IRAS values them at the last transaction price on the date of transfer. Companies cannot use that limb. For a principal holding appreciated listed positions, gifting the shares rather than selling and donating the cash can be the cleaner route, subject to personal tax advice.

Keep the giving entity separate from the investment platform. A variable capital company (VCC) is a fund vehicle, not a charity; the governance case is set out in our note on separating family giving from VCC fund operations.

Can the family’s own foundation receive 250% gifts?

Only if it is approved as an IPC, and an IPC must have an independent board. Most family-controlled foundations can register as charities but will not meet the IPC tests while the family controls the board.

The Charity Portal’s IPC criteria require that the charity’s activities benefit the community in Singapore as a whole, that at least half the governing board are Singapore citizens, and that the board meets the independence requirement in regulation 3(4) of the Charities (Institutions of A Public Character) Regulations. The founder, board members who are family members of the founder, board members related to the entity that set up the IPC, and related board members who together make up half the board are not treated as independent.

The choice is usually between a family-directed charity without IPC status, whose gifts do not attract the 250% deduction, and gifts to an established IPC, which keep the multiplier but give up control. Our comparison of Singapore trusts and companies limited by guarantee against foreign foundations covers the vehicle choice; the deduction mechanics for gifts to IPCs are also summarised in this guide to approved donations under section 37(3) of the ITA.

What should a family office do before the end of 2026?

Re-plan rather than rush. The extension removes the year-end deadline for the multiplier but leaves the PTIS commencement window and the carry-forward rules unchanged.

  1. Update board papers and donation policies that cite the old 31 December 2026 end date, and replace any reference to the Bill with Act No. 23 of 2026.
  2. Map taxable income by entity for the years of assessment 2027 to 2030 and pick the donor for each stream of giving.
  3. Split local and overseas giving. Route local gifts to IPCs for the 2.5 times deduction; route overseas gifts through PTIS or the humanitarian scheme, keeping within the shared 40% cap.
  4. If PTIS is not yet in place, decide whether to apply so that the commencement date falls on or before 31 December 2028, and budget the additional S$200,000 and the extra hire.
  5. Review any donor recognition, naming or event benefits against section 37(3G), since the deductible amount excludes the value of benefits to the donor or connected persons.
  6. Check the shareholding test before a holding company reorganisation if it has unutilised donation deductions.

The broader principal-level questions are covered in our guide to Singapore philanthropy and family office planning. Planning tools for the corporate side are on the Raffles Corporate Services free tools page.

Frequently asked questions

Is the 250% deduction now confirmed for gifts made in 2027?

Yes. Section 37(3A)(a)(ii) of the ITA, as amended by the Finance (Income Taxes) Act 2026 with effect from 4 November 2026, applies the 2.5 times multiplier to qualifying donations made up to 31 December 2029.

Did the Act extend PTIS?

No. The Act’s amendments to section 37 do not touch PTIS. IRAS still states that the 5-year PTIS period must start from an approved commencement date between 1 January 2024 and 31 December 2028.

Can unused PTIS deductions be carried forward?

No. IRAS states that unutilised overseas deductions cannot be carried forward or transferred under group relief. Only deductions for local gifts to IPCs carry forward, for up to 5 years.

Does Hong Kong have anything like PTIS?

We found no family-office-specific giving incentive in the IRD material reviewed on 8 November 2026. Hong Kong donors deduct approved charitable donations at 100%, up to 35% of assessable income or profits.

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: 8 November 2026. The Editorial Team, Variable Capital Companies Act.

Your next step.

Let’s talk about your plans.

A fund, a family office or a trust structure. We coordinate corporate work alongside experienced law firms for legal and tax advice.

Talk to our team