Singapore’s updated SFO Tax Incentive Scheme
August 2026
The Monetary Authority of Singapore (MAS) updated the tax incentive schemes for single family offices (SFOs) under sections 13O and 13U of the Income Tax Act (ITA), with new conditions in effect from 1 August 2026. The update makes a SFO materially easier to setup and administer in its first year, but also raises the bar on where a family’s wealth comes from.
Key Takeaways
- MAS's circular, effective 1 August 2026, applies to all SFO tax incentive holders under sections 13O and 13U of the Income Tax Act.
- New 13O applicants can begin with one investment professional, while 13U applicants may begin with two. The full team, including at least one non-family member, must be in place within the first year of the relevant basis period.
- AUM no longer needs to be monitored continuously. It is measured at two checkpoints: upon application and at the end of each basis period.
- Eligible charity donations can now count towards local spending requirements. Qualifying blended finance grants count at twice their value.
- AML screening widened to cover every person who contributed to a fund's source of funds, and this applies retroactively to funds approved before 1 August 2026.
- Funds without an existing Singapore bank account have a three-month grace period from 1 August 2026 to open one with a MAS-licensed institution.
Revisions for Single Family Offices
REVISION
PREVIOUSLY
NOW
Hiring requirement for investment professionals
13O funds required two qualifying investment professionals, including one non-family member, at application.
13U funds required three, including one non-family member.
13O applicants may start with one investment professional; 13U applicants may start with two. Family members may fill these initial roles.
The full team, including one non-family member, must be in place by the end of the first year of the assessment basis period.
Tracking AUM in designated investments
Continuous tracking was required throughout each basis period.
AUM is reported only at application and at the end of each basis period.
Local spending
Eligible local spending was limited to local business spending.
Eligible charitable donations and blended finance grants can now count toward local spending. Qualifying grants are counted at twice their value.
Capital deployment requirement
Capital deployment was limited to the standard qualifying categories.
The requirement is streamlined into three options. Singapore-listed equities, blended finance instruments and unlisted Singapore operating companies receive a 2x multiplier. The previous 5% cap on physical precious metals has also been removed.
AML screening and Singapore bank account
Screening covered beneficial owners, shareholders, settlors and controllers.
Screening now extends to anyone who contributed to the fund's source of funds and applies retroactively.
Funds without an account at an MAS-licensed Singapore bank have three months from 1 August 2026 to open one.
A practical comparison of the changes effective 1 August 2026
More time to build the right team
New applicants no longer need the full investment team in place on day one. A 13O applicant may start with one investment professional, while a 13U applicant may start with two. The full team, including one non-family professional, must be in place by the end of the first year of the relevant basis period.
That gives families time to recruit for fit and capability, rather than simply to meet an application deadline.
A more practical approach to AUM reporting
MAS has also replaced continuous AUM monitoring with reporting at the point of application and at the end of each basis period. That should reduce administration, particularly where portfolios move with market conditions.
The S$20 million and S$50 million thresholds remain, and family offices still need proper records and controls between reporting dates.
AML bar has been raised
The more consequential change is on anti-money laundering screening. Screenings must now cover anyone who contributed to the fund's source of funds, not only the beneficial owners, shareholders, settlors or controllers already on record. This applies retroactively, including to family offices approved before 1 August 2026.
Funds without an account at an MAS-licensed Singapore bank also have three months from 1 August 2026 to open one.
Source-of-wealth and source-of-funds records should be treated as an ongoing governance matter, not something gathered only when a bank or regulator asks.
What this means in practice
The direction is clear – the MAS is now making SFOs easier to operate, but raised the bar on governance. For families considering Singapore as a jurisdiction to setup their family office , there is less administrative friction, but greater accountability over where the wealth comes from.
In practical terms, SFOs should now focus on:
- Identify every person or entity that has contributed to the fund and confirm that the supporting source-of-funds records are complete.
- Review existing award letters and internal policies against the new standard conditions.
- Set reminders for the new AUM reporting dates and the deadline for reaching the full investment team.
- Revisit local spending and investment plans, including the wider treatment of eligible donations, blended finance and qualifying Singapore private equity investments.
Trustmoore manages the reporting cycles and revised requirements for the family offices we support, so the family can reduce their operational workload.
Why family offices keep choosing Singapore
Singapore has earned a reputation as a desirable destination for high-net-worth families seeking to professionalise the management of their money. Beyond tax incentives, its appeal lies in predictability: established financial institutions, a robust legal system and a regulatory framework that can evolve without sacrificing credibility.
By the end of 2025, more than 2,000 SFOs had been granted tax incentives, while Singapore’s asset management industry grew 10.1% over the year to reach S$6.7 trillion in assets under management. MAS has said its regulatory approach must evolve alongside the sector's growth and ambitions.
Trustmoore’s Private Clients business line
Trustmoore is an experienced provider of Private Client services, and we have been in the business for over 20 years. We understand that every family office setup can be unique, that is why our solutions are built to suit your specific needs.
As we are independent of any bank, law firm or accounting practice, we are well placed to focus exclusively on the setup and ongoing administration of your family office in Singapore. Trustmoore supports family offices from setup through ongoing administration, governance and application of tax incentives.
To discuss how these changes affect your family office in Singapore, get in touch with Desley Tan.
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