Singapore VCC insights
Foreign Fund Managers Relocating to Singapore From Hong Kong, London or Dubai: Sequencing the Move
Short answer: A fund manager moving to Singapore from Hong Kong, London or Dubai should run four workstreams in parallel: a MAS fund management licence for a Singapore entity, a plan for each existing fund, an interim delegation model that keeps the home licence alive, and work passes and tax residence for the team. Licensing is usually the critical path.
For foreign fund managers, relocating to Singapore is a sequence rather than a single event: a Singapore company is licensed, staff arrive, existing funds change manager or domicile, and the home office closes only once nothing depends on it. This guide sets out that sequence for a manager regulated by the Securities and Futures Commission (SFC) in Hong Kong, the Financial Conduct Authority (FCA) in London or the Dubai Financial Services Authority (DFSA). All Singapore and foreign sources cited were checked on 7 November 2026.
Key facts at a glance
- Section 82(1) of the Securities and Futures Act 2001 (SFA) bars carrying on business in fund management without a capital markets services (CMS) licence; the penalty is a fine of up to S$150,000, up to 3 years’ imprisonment, or both.
- MAS expects to take up to 6 months to review a complete application; an in-principle approval then gives up to 6 months to meet remaining conditions.
- The median fund management licence approval time was four and a half months in the second quarter of 2026.
- Base capital for a fund manager serving only accredited and institutional investors is S$250,000.
- A foreign fund corporation re-registered as a variable capital company (VCC) must evidence de-registration at home within 60 days (Variable Capital Companies Act 2018, s 135(6)).
- The Employment Pass floor for financial services is S$6,200 a month, rising to S$6,600 for new applications from 1 January 2027.
- A Singapore carried interest exemption for qualifying funds is expected from Year of Assessment 2027, with details at Budget 2027.
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.
How should foreign fund managers sequence a move to Singapore?
File the MAS licence application first, because it has the longest lead time and fixes the date from which the Singapore entity can lawfully manage money. Every other workstream is timed back from that date.
Two errors recur. Hiring portfolio managers into Singapore and letting them take investment decisions before the local entity is licensed risks unlicensed regulated activity. Surrendering the home licence before the Singapore licence is granted can leave funds without a qualified manager. The workable order is:
- Incorporate the Singapore company, secure a dedicated office accessible only to its directors and staff, and appoint the board.
- File Form 1 through MAS eLicensing as a licensed fund management company (LFMC), or a venture capital fund manager (VCFM) if the firm manages only venture capital funds.
- While MAS reviews, map every fund and mandate: the current manager, what the documents require to change it, and which consents are needed.
- On in-principle approval, meet the conditions and file work pass applications for the relocating team.
- Once licensed, take appointment or delegation for each fund and appoint representatives for staff performing regulated functions.
- Only then vary or cancel the home licence.
Which hub suits a given manager is covered in our comparisons of Hong Kong and Singapore, Singapore and London and the Gulf funds frameworks. This article deals with execution.
When does the Singapore entity need a MAS licence, and how long does it take?
It needs a CMS licence for fund management before carrying on that business, unless an exemption applies. MAS indicates up to 6 months to review a complete application, then up to 6 months to satisfy in-principle approval conditions, extendable by 3 months where there are strong reasons.
Section 82(1) of the SFA prohibits carrying on business in a regulated activity, or holding out as doing so, without a CMS licence, subject to the Third Schedule and s 99 exemptions. MAS’s fund management licensing page lists what it weighs: the business model, risk and compliance controls, the track record of management and major shareholders, fitness and propriety, and financial requirements. Staff performing key functions such as portfolio construction, research or client servicing must be representatives. The LFMC annual fee is a fixed S$4,000.
On 29 September 2026, MAS Deputy Chairman Chee Hong Tat said MAS had received more than 500 fund management licence applications in three years, that the median approval time was four and a half months in the second quarter of 2026, and that the quickest took 12 weeks. Our guide to building the LFMC application file covers the documents.
| Fund management business | Base capital (S$) |
|---|---|
| Collective investment schemes offered to investors other than accredited or institutional investors | 1,000,000 |
| Customers other than accredited or institutional investors | 500,000 |
| Solely as a venture capital fund manager | 0 |
| Any other case | 250,000 |
Source: item 6, First Schedule, Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations. Base capital is a floor; the business plan drives what MAS expects in practice.
What happens to the existing funds during the move?
Existing funds can stay where they are and change or add a manager, or a fund corporation can transfer its registration to Singapore as a VCC. The choice turns on the fund documents, investor appetite and whether a Singapore tax incentive is needed.
Most managers take the first route. A Cayman, British Virgin Islands or Luxembourg fund can appoint the licensed Singapore entity as investment manager, or as sub-manager under the existing manager, once its documents allow and consents are obtained. Singapore law does not require the fund itself to relocate.
The second route is Part 12 of the Variable Capital Companies Act 2018. Under s 134 the application must include certified constitutional documents from the place of incorporation, the proposed Singapore constitution, the names of the manager and directors, and the prescribed fee. After registration, s 135(6) requires evidence of de-registration at home within 60 days, which the Registrar may extend. Our note on home-country exit questions covers what to settle first.
Timing is governed by s 46. A VCC must at all times have a manager that holds a CMS licence for fund management (not a suspended one), is a person within s 99(1)(a) to (d) of the SFA, or is a prescribed person, and it cannot be its own manager. No fund should be redomiciled before the Singapore manager is licensed.
How can the home office keep managing while the Singapore licence is pending?
The home entity remains the regulated manager until the Singapore entity is licensed and appointed. In that window, Singapore staff should not take client investment decisions, and the home licence must still meet its own staffing rules.
| Home base | Regulator and licence | Point to manage |
|---|---|---|
| Hong Kong | SFC, Type 9 (asset management) | The SFC’s hedge fund licensing guide requires at least two responsible officers, at least one fully competent and ordinarily based in Hong Kong. Moving every responsible officer at once puts the licence at risk. |
| London | FCA authorisation | Section 19 of the Financial Services and Markets Act 2000 prohibits regulated activity in the UK unless authorised or exempt, so permissions must stay in place while a UK team still manages assets. |
| Dubai | DFSA licence | The DFSA regulates financial services conducted in or from the Dubai International Financial Centre, including asset management. Keep the licence and staffing intact until its funds have moved. |
Once the Singapore entity is licensed, a common bridge is sub-management: the home entity stays as appointed manager while the Singapore entity manages the portfolio under delegation. Investors and fund boards then consent to one change at a convenient date, and the Singapore firm builds an operating record before the home licence goes. Our sister site explains MAS representative notifications for fund management staff.
Which work passes do the relocating team need?
Most staff will hold an Employment Pass (EP). The most senior may qualify for the Overseas Networks & Expertise Pass (ONE Pass), which a planned Investment Management Track will open further from late January 2027.
The Ministry of Manpower (MOM) sets the financial services EP floor at S$6,200 a month, 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. Applications must score 40 points under the Complementarity Assessment Framework (COMPASS), but candidates earning a fixed S$22,500 a month or more, and overseas intra-corporate transferees, are exempt.
The ONE Pass requires a fixed monthly salary of at least S$30,000 for the 12 consecutive months before applying, or from a prospective Singapore employer, and is renewable for 5 years at a time. Mr Chee said the Investment Management Track will allow the S$30,000 test to be met with at least S$15,000 fixed pay plus variable compensation, if met for each of the past three years. MOM’s page did not yet list the track on 7 November 2026; our sister site’s ONE Pass Investment Management Track guide follows it.
How is carried interest taxed when a fund manager relocates?
Carry earned across two jurisdictions can be taxed by both, so the move date and workday records matter. The UK taxes carry as trading income apportioned by UK workdays; Singapore plans an exemption for carry from qualifying funds from Year of Assessment 2027.
For London managers, s 58 of the Finance Act 2026, effective for 2026-27 onwards, treats carry as profits of a deemed trade: non-qualifying carry plus 72.5% of qualifying carry. New s 23K of the Income Tax (Trading and Other Income) Act 2005 apportions the trade by workdays, a UK workday being one with more than 3 hours of investment management services in the UK. For a non-UK resident, certain UK workdays are ignored when apportioning qualifying profits, including those in a “non-UK tax year” (non-resident with fewer than 60 UK workdays) and those before a run of 3 or more such years. Departing managers should keep day-by-day records. The text is on legislation.gov.uk.
In Singapore, MAS announced on 19 August 2026 a planned exemption for profit-related returns from managing funds that qualify under ss 13D, 13O, 13OA, 13U or 13V of the Income Tax Act 1947 and are managed by Singapore-based fund managers. Mr Chee said it will cover income earned in the 2026 basis period. Details, and the legislation, are due at Budget 2027; see our analysis of the carried interest tax exemption.
Personal tax residence is separate. IRAS treats a foreigner as resident for a Year of Assessment after at least 183 days in Singapore in the previous calendar year, or 3 consecutive years. Its 2-year administrative concession excludes company directors, which often catches founders on the Singapore manager’s board.
What does a realistic relocation timeline look like?
For an established manager with a complete application, 9 to 12 months from filing to closing the home office is a reasonable planning assumption. The phases below are illustrative.
| Phase | Indicative timing | Singapore | Home country |
|---|---|---|---|
| Preparation | Months 0 to 2 | Incorporate, lease office, prepare Form 1 | Review fund documents; start workday records |
| MAS review | About 4 to 6 months | Answer MAS queries; recruit | Business as usual |
| In-principle approval | Up to 6 months | Capital, systems, work passes | Plan order of manager changes |
| Licensed | From grant | Take delegation or appointment | Reduce team within licence rules |
| Exit | After funds move | Complete any VCC transfer within 60 days | Vary or cancel home licence |
Set-up and fee estimates can be run on our sister site’s free tools page.
Frequently asked questions
Can our Singapore staff manage the funds before the MAS licence is granted?
Not if that amounts to carrying on fund management business in Singapore, which s 82 of the SFA reserves to CMS licence holders. Staff can prepare the business and do work that is not regulated activity.
Do we have to move the funds themselves to Singapore?
No. Foreign funds can appoint a Singapore-licensed manager. Transferring a fund corporation to Singapore as a VCC under Part 12 of the VCC Act is optional.
Can a Hong Kong manager move all its responsible officers to Singapore?
Not while it keeps its Type 9 licence, because the SFC expects at least one fully competent responsible officer ordinarily based in Hong Kong.
Is the ONE Pass Investment Management Track available now?
Not yet. MAS has said it starts in late January 2027. Until then, senior staff use the standard ONE Pass or an Employment Pass.
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: 7 November 2026. The Editorial Team, Variable Capital Companies Act.
