Singapore VCC insights

Singapore and Hong Kong Family Office: Running One Office Across Both Hubs

By VCC Editorial Team · Published 5 November 2026

Short answer: A family can operate in both hubs, but not as one undivided office. Singapore’s fund incentives need a Singapore-resident fund managed by a Singapore family office with Singapore tax-resident investment professionals. Hong Kong’s concession needs a vehicle managed or controlled in Hong Kong with two full-time Hong Kong staff. Most families run two pools with written decision rights.

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.

Many Greater China families now want a Singapore and Hong Kong family office at the same time: a Singapore base for the principal or the next generation, and a Hong Kong desk close to mainland deal flow and long-standing banking relationships. The question is not which hub wins but how one family’s investment function can sit across two regimes that each insist decisions are taken locally. This article sets out the workable operating models and the licensing, residence, substance and reporting rules each must satisfy. All sources were checked on 28 October 2026 and re-checked on 5 November 2026.

Can one family run a Singapore and Hong Kong family office at the same time?

Yes, but each hub’s concession is tied to management in that hub, so the realistic design is two legal pools of assets, each managed where it is booked. A single vehicle cannot sensibly claim both regimes.

MAS FDD Circular 05/2026 describes section 13O funds as “companies incorporated and resident in Singapore”, with residence tied to “control and management of its business” being exercised in Singapore (Annex 6), and requires the fund to be “managed or advised directly throughout each basis period” by an SFO in Singapore. Hong Kong’s FIHV concession asks the opposite: the vehicle “must be normally managed or controlled in Hong Kong”, its eligible SFO must itself be normally managed or controlled in Hong Kong, and qualifying transactions “must be carried out in Hong Kong by or through an eligible SFO” or arranged in Hong Kong by it. A vehicle run from Singapore fails the Hong Kong test; one run from Hong Kong fails the Singapore test. Our comparison of the FIHV and 13O tests line by line treats them as alternatives; this article assumes the family wants both.

Which operating models work for a dual-hub family office?

Three models are workable; a fourth, booking in Singapore with the decision-makers in Hong Kong, usually is not.

Model	How it works	Regulatory fit	Pressure point
Mirror pools	A Singapore SFO manages a 13O or 13U fund; a Hong Kong SFO manages an FIHV, each with its own team and board.	Each pool can meet its own hub’s conditions in full.	Two cost bases and two headcount floors.
Split by asset class	For example, mainland and Hong Kong private deals in the FIHV; global listed and fund portfolios in the Singapore fund.	Good, if each team genuinely decides for its own pool.	Allocation of new opportunities must be documented.
Hub and service desk	One hub runs the incentivised vehicle; the other office researches and reports but does not decide.	Possible, subject to licensing and tax analysis of the desk’s fees.	Research staff drifting into decisions.
Book in Singapore, decide in Hong Kong	Singapore fund company; Hong Kong team takes the real decisions.	Poor. Undermines Singapore residence and the 13O management condition without meeting the FIHV tests.	Hong Kong profits tax and loss of the Singapore exemption.

Families usually drift into the fourth model by accident, when a senior portfolio manager moves to Hong Kong but keeps running the Singapore book.

Does each office need a licence?

A Singapore SFO meeting the exemption conditions needs no capital markets services licence but must be a Singapore company and notify MAS. In Hong Kong, licensing turns on the activity rather than the label, and a genuine single family office serving only its group generally falls outside it.

The MAS FAQs on the licensing exemption framework (12 June 2026) require fund management only for the family (including family trusts and wholly owned family corporations), family-funded charities and key employees, family funding, incorporation in Singapore and accounts with a MAS-licensed bank (foreign-incorporated vehicles may use a regulated bank in a FATF-consistent jurisdiction). A new SFO notifies MAS within 14 days of starting operations; annual returns are due within four months of financial year end.

The Securities and Futures Commission (SFC) FAQ on family offices (8 September 2020) describes an “intra-group carve-out for a single family office where it provides such services solely to its related entities”: its wholly owned subsidiaries, a holding company holding all its issued shares, or that holding company’s other wholly owned subsidiaries. A single family office not run as a business, receiving only reimbursement of expenses, “should not in the ordinary course be considered as carrying on a business from a licensing perspective.” The lesson is ownership design: placing the Hong Kong SFO and its vehicles under one wholly owned family holding company keeps the analysis clean. Separately, an eligible SFO’s fees are chargeable to tax and at least 75% of its assessable profits must come from services to the family’s specified persons.

Where is each company resident for tax?

Both hubs look at where the business is controlled and managed, so the minute book, not the place of incorporation, decides.

IRAS states that a company is a Singapore tax resident “when its control and management is exercised in Singapore in the preceding calendar year”. For a variable capital company (VCC), the IRAS e-Tax Guide on the tax framework for VCCs (Fourth Edition, 22 April 2026) says “the location where the board of directors of the VCC meet to make strategic decisions is often a key factor”. In Hong Kong, the LegCo Legal Service Division report on the 2026 Bill (LC Paper No. LS35/2026) summarises the Inland Revenue Ordinance (Cap. 112) test used in the fund regimes: a corporation is resident where its “central management and control” is exercised in Hong Kong.

A 13O fund company whose board in practice decides in Hong Kong therefore risks the residence condition on which its exemption rests. Nor is there a treaty to resolve a dual-residence claim: Singapore does not appear on the Inland Revenue Department’s list of comprehensive double taxation agreements. Hold each vehicle’s board meetings, quorum and chair in its home hub, and keep the papers.

What creates tax exposure in the other hub?

In Hong Kong the trigger is carrying on a business there and earning Hong Kong-sourced profits, whatever the company’s residence. A Singapore vehicle whose trades are arranged by a Hong Kong team is the classic exposure.

The Inland Revenue Department explains that persons “carrying on any trade, profession or business in Hong Kong are chargeable to tax on all profits (excluding profits arising from the sale of capital assets) arising in or derived from Hong Kong”, that a non-resident may be charged directly or in the name of its agent, and that corporate profits tax is 8.25% on the first HK$2 million and 16.5% above. With no comprehensive treaty, there is no permanent establishment threshold to argue; domestic business and source rules apply directly. On the Singapore side, the 13O and 13U exemptions cover specified income from designated investments of an approved fund, so the nearer risk of Hong Kong-led management is losing the Singapore exemption.

How do 13O and 13U staff and spending conditions interact with the FIHV substance test?

They do not share: each hub counts only people and spending in its own territory, so budget for two independent floors.

For SFO funds approved on or after 1 August 2026, Circular 05/2026 requires a 13O fund’s SFO to employ at least 2 qualifying investment professionals (13U: 3), at least one not a family member, with permission to apply with one fewer if the full complement is hired by the end of the first basis period. They must be Singapore tax residents “earning more than S$3,500 per month”, and MAS’s scheme page says they “must be Singapore tax residents throughout the incentive period”. Minimum local spending is S$200,000 below S$250 million of assets in designated investments, S$500,000 from S$250 million to below S$2 billion, and S$1,000,000 above that. Local business spending means expenses “paid to contracting parties in Singapore”; our note on the 2026 local spending tiers covers donations and blended finance.

Hong Kong requires “at least two full-time employees in Hong Kong” and “at least HK$2 million operating expenditure incurred in Hong Kong”. Outsourcing to the eligible SFO is allowed, but the Department “will not apply a mechanical multiplication or division exercise”. Our reading: a full-time Hong Kong portfolio manager will struggle to be a Singapore tax resident throughout the year, and a fee paid by a Singapore fund to the Hong Kong office is not a payment to a Singapore contracting party. For what the two floors cost, see our regulatory cost floor across Singapore, Hong Kong and Dubai.

How does CRS reporting work across both hubs?

Both hubs apply the Common Reporting Standard (CRS), and a professionally managed family vehicle can itself be a reporting financial institution in its own hub.

The IRAS e-Tax Guide on CRS (Fourth Edition, 31 October 2025) treats an entity investing in financial assets that “is managed by an FI” as a Type B investment entity, reporting “by 31 May of the year following the calendar year” concerned. Hong Kong passed the Inland Revenue (Amendment) (Automatic Exchange of Information) Bill 2026 on 17 June 2026; from 1 January 2027 reporting financial institutions must register with the Inland Revenue Department, with tighter record-keeping and higher penalties. Map each entity’s status, where it reports, and whether family members appear as account holders or controlling persons.

Does Hong Kong’s 2026 Bill change the dual-hub design?

Not yet, and probably not in substance. It would widen FIHV investments but does not move the management or substance tests.

LS35/2026 records the first reading of the Inland Revenue (Amendment) (Preferential Tax Regimes for Funds, Family-owned Investment Holding Vehicles and Carried Interest) Bill 2026 on 24 June 2026. Clause 26 would expand FIHV qualifying investments, remove the 5% incidental transactions threshold and fully exempt family-owned special purpose entities. If passed, it commences on gazettal and applies to years of assessment beginning on or after 1 April 2025. We found no LegCo record of passage as at 5 November 2026, so plan on the current rules.

How should a family choose its Singapore and Hong Kong family office structure?

Start from where the principal and decision-makers will actually live, then fit the vehicles around them.

Family profile	Lead hub	Vehicle approach	Watch
Principal moving to Singapore; businesses and heirs in Hong Kong	Singapore	13O or 13U fund via a Singapore SFO; Hong Kong service desk	Desk drifting into decisions
Principal in Hong Kong; children in Singapore	Hong Kong	FIHV if Schedule 16C assets reach HK$240 million	Singapore entity with no real management
Investment teams in both cities	Both	Mirror pools or split by asset class under one wholly owned holding company	Allocation policy, two floors, board location
Below both incentive thresholds	One hub	Single SFO and holding company; revisit as assets grow	Paying for two offices with no incentive in either

1. Record who decides what for each pool, and where they live and meet.
2. Place both SFOs and their vehicles under one wholly owned family holding company or trust.
3. Incorporate the Singapore SFO and file the MAS Notification within 14 days of starting operations.
4. Apply for 13O or 13U and complete the investment professional headcount by the end of the first basis period.
5. Set up the Hong Kong SFO and FIHV, make the irrevocable written election and consider an advance ruling.
6. Map CRS status, then review staff locations quarterly; Singapore Employment Agency advises on work passes for staff moving to Singapore.

Banking needs the same two-hub design; see our guide to private bank onboarding in Singapore and Hong Kong, and our 2026 hub comparison for residency and salaries tax.

Frequently asked questions

Can a Singapore SFO manage a Hong Kong FIHV?

The Singapore exemption lets an SFO manage wholly owned family corporations, but the vehicle would not then qualify as an FIHV, which must be managed by an eligible SFO normally managed or controlled in Hong Kong.

Can one investment professional count in both hubs?

Not in a way we would rely on. Singapore requires tax residence throughout the incentive period; Hong Kong requires full-time employees in Hong Kong.

Is there a Singapore and Hong Kong double tax treaty?

Singapore is not on the Inland Revenue Department’s list of comprehensive agreements as at 5 November 2026, so there is no treaty tie-breaker or permanent establishment article.

Does the Hong Kong office need an SFC licence?

Not in the ordinary course if it is a genuine single family office serving only related entities and not run as a business. Profit-making services outside the wholly owned group need fresh analysis.

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
• Securities and Futures Commission: FAQs on Family Offices
• Hong Kong Government: passage of the Automatic Exchange of Information Bill 2026 (17 June 2026)

Raffles Corporate Services helps families set up and run the Singapore side of a dual-hub family office, from SFO incorporation and MAS notification to VCC structuring and 13O or 13U compliance. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 5 November 2026. The Editorial Team, Variable Capital Companies Act.