Singapore VCC insights

Singapore vs London for a Fund Manager: Licensing, Capital, Carry and Talent After the 2026 Dialogue

By VCC Editorial Team · Published 25 October 2026

Short answer: Singapore vs London is no longer a contest of tax alone. London offers deep capital and an enacted carried interest regime with an effective 32.625% additional-rate charge before National Insurance. Singapore offers a 17% corporate rate, a lighter capital floor and a proposed carry exemption. The 11th UK-Singapore Financial Dialogue changed neither licensing regime.

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 Singapore vs London question comes up most often from managers who already run a London platform and want an Asian hub, and from Asian sponsors deciding where their senior team should sit. This article compares the two at firm level. A principal’s personal exit from the UK is covered in our note on the UK non-dom moving to Singapore. All UK and Singapore sources cited were checked on 25 October 2026.

What did the 11th UK-Singapore Financial Dialogue mean for fund managers?

It deepened cooperation between regulators but did not change how a fund manager is licensed, taxed or staffed in either country. Read it as a sign of how closely the two supervisors work together. It is not a passporting arrangement.

According to the Monetary Authority of Singapore (MAS) media release of 20 October 2026, officials from HM Treasury and MAS met with the Bank of England and the Financial Conduct Authority (FCA). The four themes were:

• Digital finance: tokenisation and wholesale digital markets, the UK-Singapore AI in Finance Partnership and quantum-safe supervision.
• Capital markets: UK capital markets reforms and wider access to private capital; MAS’s Equities Market Review Group and Growth Capital Workgroup.
• Sustainable finance and the 2027 G20 and ASEAN priorities.

The UK will host the 12th Dialogue in 2027. For managers, tokenisation and AI governance are now shared supervisory topics.

Do you need FCA authorisation or a MAS licence to manage funds?

Yes, in each country, unless an exemption applies. Both regimes are built on a general ban. The difference lies in procedure and in the exemptions on offer.

In the UK, s 19 of FSMA states that no person may carry on a regulated activity in the United Kingdom unless authorised or exempt. Under s 55V, the regulator must decide a completed application within 6 months, and an incomplete one within 12 months.

In Singapore, s 82 of the Securities and Futures Act 2001 bans carrying on business in a regulated activity without a CMS licence. The ban is subject to the Third Schedule and the exemptions in s 99. Breach carries a fine of up to S$150,000, imprisonment of up to 3 years, or both. The MAS fund management licensing page says a firm conducting regulated fund management “must apply to be a licensed fund management company (LFMC)”. It also says MAS expects “up to 6 months to review applications which are complete”. After in-principle approval, the applicant has up to 6 months to meet the licensing conditions. The annual fee is a fixed S$4,000. A firm that solely manages venture capital funds may use the simplified venture capital fund manager (VCFM) regime. Class exemptions are covered in our note on the fund management exemption.

How do capital requirements compare in Singapore vs London?

For a manager of professional money, the starting floors are similar in size. The UK measure moves with the firm’s cost base, while Singapore’s base capital is a fixed sum tied to the activity and the type of client.

Item	London (FCA)	Singapore (MAS)
Legal basis	MIFIDPRU 4 in the FCA Handbook	Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations, First Schedule
Manager for professional or accredited investors only	£75,000 permanent minimum capital for portfolio management or investment advice	S$250,000 base capital (“in any other case”)
Manager holding client money or assets	£150,000	Not a separate fund management line
Discretionary management for retail customers	No separate line in MIFIDPRU 4.4.1R	S$500,000
Collective investment scheme offered to retail investors	No separate line in MIFIDPRU 4.4.1R	S$1 million
Venture capital fund manager	No separate floor in MIFIDPRU 4.4	Zero, if acting solely as a VCFM
Scaling with costs	Own funds requirement is the highest of the permanent minimum, the fixed overheads requirement (one quarter of the previous year’s relevant expenditure) and, for non-small firms, the K-factor requirement	Base capital is a fixed amount; other financial requirements in the Regulations also apply

The fixed overheads test matters most in practice. A London firm with £4 million of relevant annual expenditure would need at least £1 million of own funds under that test alone, whatever its permission.

How does SM&CR compare with Singapore’s individual accountability guidelines?

The UK regime is statutory and comes with approval and certification steps. Singapore’s equivalent works mainly through MAS guidelines and supervision.

The FCA describes the Senior Managers and Certification Regime (SM&CR) as having three parts: the Senior Managers Regime, the Certification Regime and the Conduct Rules. It was extended to solo-regulated firms in December 2019, with benchmark administrators following in December 2020. The FCA also notes that the regime “is undergoing reform as part of the government’s broader financial services agenda”. A manager setting up in London should therefore check the current rules before mapping its senior roles.

MAS issued its Guidelines on Individual Accountability and Conduct on 10 September 2020. Its release named the UK SM&CR among the overseas regimes it had considered. The guidelines set out five outcomes. Under them, senior managers responsible for core functions are clearly identified and are fit and proper. Material risk personnel are subject to effective risk governance. The firm also has a framework that promotes the desired conduct among all employees.

Which fund vehicles fit each base?

From London, a manager can work with English limited partnerships or FCA-authorised open-ended funds. A Singapore manager now has the variable capital company (VCC) on its doorstep.

Under s 8D of the Limited Partnerships Act 1907, inserted with effect from 6 April 2017, a limited partnership can be designated a private fund limited partnership. To qualify, it must be “constituted by an agreement in writing” and must be a collective investment scheme. For less liquid strategies sold more widely, the FCA’s Long-Term Asset Fund (LTAF) is “a new category of open-ended authorised fund designed to invest efficiently in long-term assets”. The first LTAF was authorised in March 2023.

In Singapore, s 46 of the Variable Capital Companies Act 2018 requires every VCC to have, at all times, a manager that holds a CMS licence for fund management, is a person within s 99(1)(a) to (d) of the Securities and Futures Act 2001, or is a prescribed person. A VCC “cannot be its own manager”. Section 46(2)(b) was deleted with effect from 6 May 2026. A London manager therefore needs a Singapore-licensed or exempt manager, its own subsidiary or a third party, to run a VCC.

How do carried interest and corporate tax compare?

London’s carry regime is enacted and gives a known effective rate. Singapore’s exemption is announced but its terms are not yet published. Singapore wins clearly on corporate and top personal income tax rates.

Section 58 of the Finance Act 2026 inserts new sections 23I to 23R into the Income Tax (Trading and Other Income) Act 2005. An individual who performs investment management services and receives carried interest “is treated as carrying on a trade”. The taxable profit is the non-qualifying carry plus “72.5% of the qualifying profits”. The new rules have effect “for the tax year 2026-27 and subsequent tax years (but in relation to investment management services whenever performed)”. At the 45% additional rate, 72.5% of qualifying carry gives an effective income tax rate of 32.625%, before Class 4 National Insurance. Non-qualifying carry is taxed in full.

The territorial rules matter for a team split between the two cities. Under the new s 23K, the trade is treated as carried on in the UK in proportion to UK workdays. A UK workday is one on which the individual spends more than 3 hours on investment management services in the UK. For a non-UK resident, a tax year with fewer than 60 UK workdays is a “non-UK tax year”. UK workdays in such years, and those before 30 October 2024, are disregarded for qualifying profits, so a Singapore-based partner who visits London should keep a day log.

In Singapore, the MAS media release of 19 August 2026 says MAS and the Ministry of Finance “plan to introduce a tax exemption for profit-related returns” from fund management services to qualifying funds. The exemption is “expected to take effect from the Year of Assessment 2027”, and “further details will be announced at Budget 2027”. Our article on the carried interest tax exemption in Singapore sets out what is known.

On corporate tax, HMRC’s published rates for the financial year starting 1 April 2026 are a 25% main rate for profits over £250,000 and a 19% small profits rate under £50,000, with marginal relief in between. IRAS states that a Singapore company “is taxed at a flat rate of 17% of its chargeable income”. For individuals, the UK additional rate is 45% on taxable income over £125,140. Singapore’s top resident rate is 24% on chargeable income above S$1,000,000 from YA 2024.

Singapore vs London for hiring senior investment talent

Singapore offers more routes for a senior hire, including one that is not tied to a single employer. The UK depends more on sponsored employment.

The UK Skilled Worker visa requires a job offer from a Home Office-approved sponsor. The salary must be at least £41,700 a year or the going rate for the occupation, whichever is higher. The Global Talent visa covers leaders or potential leaders in academia or research, arts and culture, and digital technology. It does not list finance as a field, so most investment professionals will need the Skilled Worker route unless their role fits digital technology.

In Singapore, the Ministry of Manpower (MOM) sets the EP qualifying salary for financial services at S$6,200, rising with age to S$11,800 at 45 and above. For new applications from 1 January 2027, these become S$6,600 and S$12,700. Candidates must also earn 40 points under the Complementarity Assessment Framework (COMPASS), unless their fixed monthly salary is at least S$22,500. The Overseas Networks & Expertise (ONE) Pass requires a fixed monthly salary of at least S$30,000. Where it is based on overseas employment, the employer must also be an established company, with a market capitalisation of at least US$500 million or annual revenue of at least US$200 million. The ONE Pass is renewable for 5 years at a time. MAS and MOM “intend to introduce” a ONE Pass Investment Management Track that may recognise performance-linked pay. At the time of writing, MOM’s eligibility page lists an AI and Tech track from 28 January 2027 but not yet an Investment Management Track. See our note on the ONE Pass for family offices. Our sister practice, Singapore Employment Agency, handles pass applications.

How should a manager decide between the two?

Start from where the investors and decision-makers are, then test tax and staffing costs. The answer can also be both cities, with each one doing a defined job.

1. Map the investor base and the marketing rules that apply where those investors are.
2. Decide where investment decisions are made. This decides which regulator licenses the manager and where the carry trade is treated as carried on under s 23K.
3. Choose the vehicle. A VCC needs a manager under s 46. A private fund limited partnership needs a written agreement and collective investment scheme status.
4. Model capital. Compare the UK fixed overheads requirement on your projected cost base with Singapore’s fixed base capital for your client type.
5. Model carry under both regimes. Use the enacted UK rules, and treat Singapore’s exemption as unconfirmed until Budget 2027.
6. Plan the senior team’s passes and day counts before anyone moves.

In fairness to London, its carry regime is already law and its fund toolkit is established. Singapore’s case rests on the VCC, lower tax rates and flexible senior passes. See also our Hong Kong or Singapore fund manager comparison.

Frequently asked questions

Can an FCA-authorised manager manage a Singapore VCC directly?

Not on the strength of its FCA authorisation alone. Section 46 of the Variable Capital Companies Act 2018 requires a manager that holds a Singapore CMS licence for fund management, falls within s 99(1)(a) to (d) of the Securities and Futures Act 2001, or is a prescribed person.

Did the UK-Singapore Financial Dialogue create mutual recognition for fund managers?

No. The MAS release of 20 October 2026 describes regulatory cooperation and announces no recognition or passporting for fund managers.

Is UK carried interest still taxed as a capital gain?

Not from 2026-27. Finance Act 2026, s 58 treats carried interest as profits of a deemed trade. Only 72.5% of qualifying carry is brought into charge.

Is Singapore’s carried interest exemption law yet?

No. MAS describes it as a planned exemption expected to take effect from YA 2027, with details at Budget 2027.

What is the minimum capital for a Singapore fund manager serving accredited investors?

S$250,000 base capital under the First Schedule to the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations. It is higher for retail business and zero for a manager acting solely as a venture capital fund manager.

Sources

• MAS: The UK and Singapore Hold 11th UK-Singapore Financial Dialogue (20 October 2026)
• Finance Act 2026, section 58: Carried interest
• Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations
• MAS: Fund Management Licensing
• HMRC: Corporation Tax rates and allowances

Raffles Corporate Services helps fund managers and family offices choosing Singapore as their Asian base with VCC incorporation, family office set-up and ongoing compliance, and works alongside licensed managers and law firms on the regulatory steps. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 25 October 2026. The Editorial Team, Variable Capital Companies Act.