A family office principal who qualifies to live and work in Singapore under ONE Pass or the Global Investor Programme (GIP) still has a separate obligation to meet: the Monetary Authority of Singapore’s (MAS) local investment professional headcount for the Single Family Office claiming tax incentives under Section 13O or Section 13U of the Income Tax Act 1947. The immigration pass and the tax incentive headcount are governed by different agencies and different timelines, and conflating them is one of the more common planning errors seen in new family office set-ups.
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
What ONE Pass and GIP actually require
The Overseas Networks and Expertise (ONE) Pass is a five-year, employer-independent work pass administered by the Ministry of Manpower (MOM). The main eligibility route requires a fixed monthly salary of at least S$30,000, either drawn from the applicant’s current or recent overseas role at an established company over the preceding 12 months, or from a confirmed Singapore-based offer at the same salary level, with employment starting within six months of application. Fixed monthly salary means basic salary plus fixed allowances; variable bonuses, commissions and employer pension contributions are generally excluded from the calculation. ONE Pass holders may work for, found or direct more than one entity in Singapore, which is part of why it is used by principals who also sit across a family office and its related investment vehicles.
The Global Investor Programme, administered by the Economic Development Board (EDB), is a permanent residence route for substantial investors, not an employment pass. It has three current options: Option A requires an investment of at least S$10 million in a new or existing Singapore business, a five-year business plan, at least 30 percent shareholding and an active management role; Option B requires at least S$25 million invested in an EDB-approved GIP-select fund; and Option C requires establishing a Singapore Single Family Office with assets under management of at least S$200 million, of which at least S$50 million must be transferred to Singapore and deployed into EDB-specified investments within 12 months of final approval. GIP applicants should always confirm current thresholds against the EDB’s published factsheet, since investment programme terms are reviewed periodically.
Neither ONE Pass nor GIP, on their own, satisfies or substitutes for the MAS investment professional headcount that gates the Section 13O or 13U tax incentive. They solve the principal’s own right to live and work (or obtain residence) in Singapore; the headcount is a separate condition attached to the family office entity’s tax incentive application.
The MAS headcount condition, separately
Under the Section 13O scheme (for Single Family Offices with smaller funds, typically run through a Singapore-incorporated company), applicants must employ at least two investment professionals based in Singapore, at least one of whom must not be a family member, with the full headcount to be in place within the first year of the relevant basis period; MAS introduced flexibility allowing a new 13O applicant to begin with one investment professional at the point of application, provided the full team is built up within that first year. Under Section 13U (for larger funds, typically run through a Singapore variable capital company or other qualifying vehicle), the established requirement is at least three investment professionals, at least one of whom must not be a family member, with newer applicants permitted to start with two at application. These figures should always be checked against the current MAS circulars at the time of application, since family office tax incentive conditions have been revised more than once in recent years.
Decision tree: sequencing the principal’s pass against the headcount build-out
- If the principal is also one of the investment professionals: confirm whether the principal’s own qualifications and time commitment can be counted toward the headcount, and whether MOM’s pass of choice (ONE Pass, Employment Pass, or entry via GIP residence) is compatible with being an employee or director of the family office entity for MAS’s purposes. A principal who is Singapore tax resident under GIP but spends limited time in Singapore may not satisfy MAS’s expectation of a Singapore-based investment professional actively managing the portfolio.
- If the principal intends to hire externally for the non-family investment professional role(s): sequence the hiring process so that the non-family hire’s own pass (typically an Employment Pass, assessed against MOM’s points-based framework) is secured before or alongside the MAS tax incentive application, since MAS will expect to see the headcount either in place or on a committed timeline at the point of review.
- If the principal is entering via GIP Option C (the family office route): recognise that the S$200 million AUM and S$50 million deployment conditions sit on top of, not instead of, the MAS investment professional headcount for the 13O or 13U incentive the office will typically also apply for. These are two separate approval processes, from two different agencies, that commonly run in parallel.
A worked illustration
Consider a founder who has sold an operating business overseas and intends to relocate to Singapore to run a single family office for the resulting wealth. The founder qualifies for ONE Pass on the salary route, having earned above S$30,000 a month at the overseas company over the preceding year, and separately plans to apply for the Section 13O tax incentive for a newly incorporated family office vehicle with roughly S$15 million in assets under management. Under this scenario, the founder’s ONE Pass secures the right to live and work in Singapore without being tied to a single employer, which is useful because the founder will likely sit across the family office entity and one or two related investment holding companies. Separately, and on its own timeline, the family office must recruit at least one additional investment professional (since the founder alone is unlikely to satisfy both the headcount and the non-family member condition), confirm whether the founder’s own role counts toward the two-person minimum, and build the team to the full requirement within the first year of the relevant basis period. If the founder instead pursued Singapore residence through GIP Option C, with at least S$200 million in assets under management and at least S$50 million deployed into Singapore within 12 months, the same separation applies: the GIP approval addresses residence, and the 13O or 13U tax incentive and its headcount addresses the fund vehicle’s tax treatment. Running these two work streams on a shared timeline, rather than assuming one approval automatically satisfies the other, is the practical takeaway for most new family office set-ups.
Cost considerations
Beyond MOM and EDB application costs, the main additional cost driven by the MAS headcount condition is the salary cost of the non-family investment professional hire, or hires, which varies considerably with seniority and specialisation but is a real and recurring cost that should be budgeted into the family office’s operating model from the outset, not treated as an afterthought once the tax incentive application is already in motion. Recruitment costs and the time cost of a search for a suitably qualified investment professional should also be factored into the planning timeline, particularly for offices targeting the full headcount within a tight first-year window.
Numbers and timelines
ONE Pass applications are assessed against the S$30,000 fixed monthly salary threshold and are typically processed within a matter of weeks once the supporting salary evidence is in order, though processing times vary with case complexity. GIP applications run on a longer timeline, commonly several months from submission to final approval, given the scale of due diligence on the source of funds and the investment plan. Building out the MAS investment professional headcount from one or two to the full requirement within the first year of the relevant basis period is itself a recruitment exercise that should start early, since qualified investment professionals with the right regulatory and portfolio management background are not always readily available on short notice in the Singapore market.
Common mistakes
- Assuming the principal’s own ONE Pass or GIP approval satisfies the MAS headcount. It does not; the headcount is assessed separately by MAS as a condition of the tax incentive, not by MOM or EDB as a condition of the pass or residence status.
- Leaving the non-family investment professional hire to the last minute. Because at least one role must go to a non-family member, and because that hire often also needs their own work pass if they are a foreigner, this hiring process should start well before the tax incentive application is due.
- Treating the headcount as a one-time hurdle. MAS expects the headcount to be maintained, not just reached once; a family office that lets headcount lapse after initial approval risks its ongoing tax incentive status.
- Not confirming current thresholds before applying. Family office tax incentive conditions, including the minimum headcount and the flexibility to start with fewer investment professionals, have been revised in recent years; applicants should confirm the version in force at the time of their application directly against MAS’s published circulars rather than relying on older commentary.
Frequently asked questions
Can the family office principal count as one of the required investment professionals?
This depends on the principal’s role, qualifications and time actually spent managing the portfolio in Singapore, and on whether MAS’s conditions for that specific incentive treat the principal as an eligible investment professional. This is a case-specific assessment that should be confirmed with a qualified adviser before the application is filed.
Does GIP Option C require the family office to also hold a 13O or 13U tax incentive?
GIP Option C is itself a residence route based on establishing and funding a Single Family Office; many applicants separately apply for the Section 13O or 13U tax incentive for the office’s fund vehicle, but the GIP approval and the tax incentive approval are distinct processes assessed by different agencies.
What happens if the headcount is not met within the first year?
Failing to meet the committed headcount within the stipulated period can put the tax incentive status at risk; family offices in this position should engage with MAS proactively rather than waiting to be queried.
Is the non-family investment professional required to be Singaporean?
The non-family member condition is about family relationship to the principal, not nationality; a non-family foreign hire would typically still need an appropriate MOM work pass to be employed in Singapore.
Where should current MAS headcount figures be checked?
Against MAS’s published circulars and guidelines on the Section 13O and 13U schemes, since the specific numbers and start-up flexibility have changed more than once and should not be assumed from older articles, including this one, without reconfirming the current position.
Who should read this
This article is written for founders and principals who have already cleared, or are close to clearing, the ONE Pass or GIP eligibility bar and are now turning to the operational question of standing up the family office entity itself. It assumes the reader already understands, at a high level, the difference between a Section 13O and a Section 13U tax incentive application; readers newer to that distinction should start with our broader guide on setting up a family office before working through the headcount sequencing issues covered here.
Related guides
For the underlying tax incentive comparison, see our guide on Section 13O vs 13U family office set-up in Singapore. For the hiring side of building out a team around a family office, see our partner site’s guide on hiring foreign professionals and the total cost model, and for director and local headcount considerations at the corporate entity level, see foreign director vs local resident director requirements for a Singapore Pte Ltd.
Authority sources
This article draws on guidance from the Monetary Authority of Singapore, the Inland Revenue Authority of Singapore, and professional conduct standards referenced by the Law Society of Singapore for advisers supporting family office structuring.
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.