13O vs 13U: Which Singapore Fund Tax Incentive Do I Qualify For?
The side-by-side comparison — AUM, headcount, domicile and cost, with the current 2026 numbers.
13O vs 13U is the first real decision most fund managers and family offices face. Both are Singapore tax-exemption schemes administered with the Monetary Authority of Singapore (MAS), and both exempt qualifying income from designated investments. The difference is scale and substance: Section 13O is the onshore scheme for smaller funds (around S$5M AUM, two investment professionals), while Section 13U (the Enhanced Tier) targets larger and institutional funds (S$50M AUM, three investment professionals, onshore or offshore).
This page is part of the Singapore fund tax incentives hub. Most managers pair either scheme with a VCC; family offices follow the same logic — see family office structures.
13O vs 13U: the full comparison
Here is the canonical side-by-side. Sources disagree online because they conflate the general fund rules with the family-office route and mix pre- and post-2025 figures. This is the current position:
| Feature | Section 13O (Onshore) | Section 13U (Enhanced Tier) |
|---|---|---|
| Best for | Smaller onshore funds, single-family offices | Larger funds, multi-family offices, institutional mandates |
| Minimum AUM | S$5M in designated investments (end of each FY) | S$50M at application and each FY |
| Upper AUM limit | None, but funds usually graduate to 13U | None |
| Investment professionals | ≥2 (≥1 non-family) | ≥3 (≥1 non-family) |
| Fund domicile | Onshore (Singapore) | Onshore & offshore |
| Local business spending | Tiered: <S$250M → S$200k · S$250M–2B → S$300k · >S$2B → S$500k | |
| MAS application | Required | Required |
| AUM test timing | End of each financial year | At application and end of each financial year |
| Typical run cost | Lower (smaller team) | Higher (larger team, more spend) |
| Investor perception | Solid for family/private capital | Preferred / expected by institutional LPs |
Which one do I qualify for?
The short logic:
- Under S$5M AUM: you fall short of 13O for now — see our near-miss tips and consider building toward the S$5M floor.
- S$5M–S$50M with two investment professionals: you are in 13O territory.
- S$50M+ with a third investment professional: 13U becomes available and is usually preferred.
- Singapore limited partnership: use Section 13OA.
- Purely offshore vehicle managed from Singapore: look at Section 13D.
As a quick decision matrix:
| Your situation | Scheme you fit | What you must clear |
|---|---|---|
| Singapore company / VCC, S$5M–S$50M AUM, 2 investment pros | 13O | S$5M designated investments at each FY-end · ≥2 IPs (≥1 non-family) · tiered local spend |
| Singapore or offshore fund, S$50M+ AUM, institutional investors | 13U | S$50M at application & each FY · ≥3 IPs (≥1 non-family) · tiered local spend |
| Singapore limited partnership | 13OA | 13O conditions applied at the LP level |
| Purely offshore vehicle, managed from Singapore | 13D | No minimum AUM · ≥1 IP from FY-end 2027 · no MAS application |
| Under S$5M AUM today | Not yet eligible | Build toward the S$5M floor, then apply for 13O |
The eligibility checker maps your specifics — structure, AUM band, headcount and investor type — and returns the scheme you fit plus the exact numbers you still need to hit.
Can I start on 13O and upgrade to 13U later?
Yes, and many do. A common path is launching under 13O, then applying afresh to MAS for an Enhanced Tier award once AUM crosses S$50M and the third investment professional is hired. A VCC umbrella makes this cleaner, because new sub-funds can be added under the same award. We cover the mechanics in how to apply via MAS and the substance rules in economic substance & 2025–2027 changes.
Still not sure which fits?
Run the 13O/13U eligibility checker, then we'll connect you with a vetted Singapore fund-setup partner to file it.
Check my eligibility →Frequently asked questions
What is the main difference between 13O and 13U?
Scale. 13O needs S$5M AUM and two investment professionals; 13U needs S$50M and three. 13O is onshore-only; 13U covers onshore and offshore vehicles with no upper size limit.
Can I start on 13O and move to 13U later?
Yes. Many managers launch under 13O and apply for an Enhanced Tier (13U) award once AUM crosses S$50M and a third investment professional is in place. You apply afresh to MAS for the 13U award.
Which scheme is cheaper to run?
13O is generally cheaper because it needs fewer investment professionals and a lower AUM base. Local business spending tiers are identical, so the difference is mainly headcount and the larger team a 13U fund typically carries.
Do both schemes use the same local business spending tiers?
Yes. Both 13O and 13U use the tiered scale: below S$250M AUM requires S$200k, S$250M-2B requires S$300k, and above S$2B requires S$500k per year.
VCC Singapore is an independent informational resource and is not a regulator, law firm or tax adviser. Tax thresholds and conditions are set by MAS/IRAS and change periodically — confirm the current figures before acting. This page is general information, not legal, tax or financial advice.