
A GIP family office planning employment commitments should identify which roles already exist and which are genuinely additional. A total headcount without a baseline can obscure whether an incremental-employment condition has been met.
Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.
The EDB GIP factsheet addresses incremental family-office professionals under Option C’s renewal criteria. For investment in an existing office, its footnote ties incremental employment to the application-submission baseline. Review the actual renewal route and undertaking, rather than treating every employee as additional.
Preserve the baseline
Collect the relevant staff list, employment agreements and payroll evidence at the applicable starting point. Identify the legal employer and roles. A later spreadsheet reconstructed from memory is weaker than contemporaneous records.
Record existing vacancies separately from employees actually engaged. An unfilled position should not be shown as an employee merely because the business plan contains a salary budget.
Example: an established office hires replacements
An office begins with several staff and replaces departing employees. The hiring schedule should show departures, replacements and genuinely additional positions. Do not count every new employment contract as an increase without comparing the baseline and actual conditions.
Create a movement schedule
- Employee and legal employer.
- Role and relevant function.
- Start and cessation dates.
- Existing, replacement or additional position.
- Citizenship information relevant to the applicable requirement.
- Payroll and other supporting evidence.
Explain group transfers and secondments accurately. Employment by another related company does not necessarily establish the applicant office’s own headcount.
Keep GIP and fund-tax tests distinct
A role may need assessment under more than one framework, but the definitions and timing need not be identical. GIP employment criteria and MAS investment-professional conditions should be reviewed separately.
Our investment-professional employer review addresses one of those distinct checks. Do not assume qualification under one programme proves qualification under another.
Make the business plan operational
Identify the genuine work, budget, recruitment lead time and responsible manager for each planned role. Review employment contracts and work-authorisation requirements where relevant. Nominal positions or unsupported payroll entries should not be used to present an artificial staffing result.
Give the decision-makers a realistic plan for gaps and turnover. A role disappearing before the relevant assessment can change the evidence even if the earlier hiring target was reached.
Review before the renewal stage
Reconcile the movement schedule to current records and the applicable official requirements. Keep other investment and residence conditions on the review calendar as well. A headcount schedule is not the whole renewal assessment.
Does every new hire count as incremental?
Review the baseline, departures and applicable conditions. A replacement is not automatically an additional role.
Can the MAS headcount schedule be reused unchanged?
Only after checking the distinct GIP definitions, timing and evidence.
Related relocation and business resources
Read our PR service overview, Employment Pass guidance and family-office setup resources.
Discuss the business and relocation evidence
For company administration, financial records and relocation advisory support, email [email protected] or WhatsApp +65 8501 7133. Our tax advisers and legal advisers from associated law firms can assist with the relevant financial, contractual and structuring questions. Raffles Corporate Services is not affiliated with EDB or ICA, and no application outcome is guaranteed.
Let’s talk