Families setting up a Singapore family office increasingly hold assets and family members across more than one jurisdiction, which raises questions about licensing, tax residency and how a Singapore single family office (SFO) fits alongside existing structures elsewhere. This article answers the questions we hear most often from families structuring across borders.
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
What changed for Singapore family offices in 2026
MAS’s Revised Framework for Single Family Offices took effect on 15 June 2026, replacing the previous patchwork of the related-corporation exemption and MAS’s case-by-case bespoke exemptions that many trust- and foundation-held family offices previously relied on. The new framework is notification-based rather than application-based: an SFO notifies MAS within 14 days of commencing business, rather than seeking prior approval, provided it meets the framework’s conditions. Existing SFOs operating under the older exemptions have a one-year transition period to 15 June 2027 to move onto the new framework.
Who this affects
This affects multi-generational families setting up or restructuring a Singapore family office, families with existing family offices in other jurisdictions (Hong Kong, Switzerland, Dubai) considering adding or relocating to a Singapore SFO, and family offices structured through a trust or foundation rather than a company, who previously had a less clear regulatory path in Singapore than corporate SFOs.
Key conditions of the 2026 framework
The revised framework is structure-agnostic, accommodating an SFO set up as a company, trust or foundation. Funding must come exclusively from family members, defined broadly to include up to five generations from a common ancestor and extending indefinitely to lineal descendants, plus key employees, whose collective interest is capped at 10% of the SFO’s assets under management. The SFO must be incorporated or established in Singapore, and both the SFO itself and each fund vehicle it manages must maintain bank accounts with a MAS-licensed bank. Annual reporting is simplified to a return covering total assets under management and a list of banks used, rather than granular portfolio-level disclosure, due within four months of the financial year end.
How this differs from the section 13O tax exemption
A common point of confusion is treating the SFO licensing exemption and the section 13O tax exemption scheme as the same thing; they are separate MAS-administered regimes addressing different questions. The licensing exemption governs whether the SFO can manage money without a full fund management licence. The section 13O scheme, under the Income Tax Act 1947, is a separate application for tax exemption on specified income, and since 5 July 2023 requires a minimum of S$20 million in assets under management at the point of application, maintained throughout the incentive period, with further economic substance conditions tightened from 1 January 2026. A family office can hold an SFO licensing exemption without applying for section 13O, though most substantial family offices pursue both.
Numerical specifics to plan around
Key figures for 2026: no minimum AUM threshold applies to the SFO licensing exemption itself; the section 13O scheme requires S$20 million AUM at application; key employee participation in an SFO is capped at 10% of AUM; SFOs have 14 days from commencing business to notify MAS under the new framework; and existing SFOs have until 15 June 2027 to transition from the older exemption regime.
Multi-jurisdiction structuring considerations
Families with an existing family office in Hong Kong, Switzerland or Dubai considering Singapore should think of the Singapore SFO as a distinct regulated entity, not an extension of the overseas office; each jurisdiction’s licensing regime, tax treatment and reporting obligations apply independently, even where the same family and the same underlying assets are involved. Our comparison of Singapore versus Hong Kong, Dubai (DIFC) and Switzerland for family office set-up in 2026 sets out how the regulatory, tax and lifestyle considerations compare across these four hubs, which is a useful starting point before deciding where a new SFO or fund vehicle should sit.
Using a VCC alongside a family office
Families increasingly use a Variable Capital Company as the investment vehicle managed by the family office, keeping the SFO itself focused on management and governance while the VCC holds the actual portfolio. Our related article on VCC for family office investment vehicles, eligibility and requirements covers this structure in detail, including how sub-funds can be used to separate different family branches’ allocations.
Relocating family members alongside the family office
Setting up a Singapore SFO often coincides with relocating some family members to Singapore, and sequencing PR or citizenship applications for children of different ages is a common practical wrinkle; our guide on sequencing PR and citizenship applications for children at different ages addresses this directly for families going through both processes at once.
Governance implications of the 14-day notification window
Families setting up a Singapore SFO should note that the 14-day notification window under the 2026 framework starts running from when the SFO commences business, not from when incorporation paperwork is filed, which means the governance structure, bank accounts and family funding documentation should ideally be substantially ready before the SFO begins actively managing money. Families who start operating informally before these pieces are in place risk finding themselves already inside the 14-day window without having gathered everything MAS expects to see in the notification.
Coordinating family office and operating company governance
Many families running a Singapore SFO alongside an operating business, such as a manufacturing company or trading business the family also owns, benefit from keeping SFO governance clearly separate from the operating company’s own board and management, even where some family members sit on both. Mixing the two can create confusion over which entity’s funds are being used for what purpose, and MAS’s simplified annual return for SFOs specifically expects a clean total AUM figure for the SFO itself, not commingled with operating business figures.
FAQs
Does a Singapore SFO need MAS approval before starting operations? No, under the framework effective 15 June 2026, an SFO notifies MAS within 14 days of commencing business rather than seeking prior approval, provided it meets the framework’s conditions.
Can a trust-based family office use the new exemption? Yes, the revised framework is structure-agnostic and accommodates SFOs structured as a company, trust or foundation.
Is there a minimum AUM to qualify for the SFO licensing exemption? No minimum AUM applies to the licensing exemption itself, though the separate section 13O tax scheme requires S$20 million AUM at application.
Can family offices in other jurisdictions simply extend their licence to Singapore? No, a Singapore SFO is a distinct entity subject to Singapore’s own regulatory framework, incorporation requirements and reporting obligations.
What happens to SFOs currently operating under the older exemptions? They have a one-year transition period, until 15 June 2027, to move onto the new notification-based framework.
For official guidance, refer to MAS’s fund tax incentive scheme information for family offices, IRAS for section 13O application requirements, and the Singapore Economic Development Board for how family office set-up intersects with the Global Investor Programme for relocating principals.
Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email [email protected]. Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.