Section 13D: Singapore's Offshore Fund Tax Exemption
The offshore scheme with no AUM minimum and no MAS application — what it covers and when an onshore scheme beats it.
Section 13D (formerly Section 13CA) is Singapore's offshore fund tax exemption, administered under the Income Tax Act. It exempts qualifying income on designated investments earned by an offshore-domiciled fund that is managed by a Singapore-based fund manager. Its defining features are simplicity: unlike Section 13O and Section 13U, 13D has no minimum AUM and requires no formal application to MAS — it is self-assessed, provided the conditions are met and documented.
This page is part of the Singapore fund tax incentives hub. If your vehicle is onshore — a Singapore company or VCC — an onshore scheme is usually the better fit; the 13O vs 13U comparison covers those.
What is Section 13D?
13D exempts the specified income of an offshore fund — one that is not a Singapore tax resident and is not 100% beneficially owned by Singapore investors — where the fund is managed or advised by a fund manager operating in Singapore. It lets a Singapore manager run an offshore vehicle (for example a Cayman or BVI structure) without the offshore fund itself being taxed in Singapore on its designated-investment income.
Who qualifies for Section 13D?
- The fund is an offshore vehicle (not Singapore-incorporated, not Singapore tax-resident);
- It is managed or advised by a Singapore-based fund manager (MAS-licensed or exempt);
- Its income is from designated investments; and
- It satisfies the qualifying-investor and ownership conditions (broadly, not wholly owned by Singapore-resident non-individual investors).
Why is there no MAS application or AUM minimum?
13D was designed to let Singapore compete as a fund-management hub for offshore vehicles without the friction of an approval process. Because the fund is offshore, the exemption is self-assessed at the fund level — there is no S$5M or S$50M floor and no award letter. The trade-off is less formal certainty and, from the financial year ending 2027, a new economic-substance condition expected to require at least one investment professional.
13D vs 13O vs 13U — when does offshore win?
| Feature | Section 13D (Offshore) | Section 13O (Onshore) | Section 13U (Enhanced Tier) |
|---|---|---|---|
| Fund domicile | Offshore | Onshore (Singapore) | Onshore & offshore |
| Minimum AUM | None | S$5M | S$50M |
| MAS application | No | Yes | Yes |
| Investment professionals | ≥1 (from FY-end 2027) | ≥2 (≥1 non-family) | ≥3 (≥1 non-family) |
| Local business spending | None | Tiered S$200k / S$300k / S$500k | |
Choose 13D when the fund is genuinely offshore and you want minimal friction. Choose 13O or 13U when you want an onshore vehicle, a formal MAS award and the substance signal that institutional and family-office investors look for — see family office structures.
Offshore vehicle, Singapore manager?
Tell us your structure and we'll connect you with a vetted Singapore fund-setup partner to confirm whether 13D or an onshore scheme fits.
Check my eligibility →Frequently asked questions
What is Section 13D?
Section 13D (formerly 13CA) is Singapore's tax exemption for offshore funds managed by a Singapore-based fund manager. It exempts qualifying income on designated investments without a formal MAS application or AUM minimum.
Does Section 13D require a MAS application?
No. Unlike 13O and 13U, the 13D offshore exemption is self-assessed and does not require an upfront MAS application or award letter, though conditions must still be met and documented.
Is there a minimum AUM for 13D?
No. Section 13D has no minimum AUM threshold. From the financial year ending 2027, however, an economic-substance condition of at least one investment professional is expected to apply.
When should I choose 13O instead of 13D?
Choose 13O if your fund vehicle is onshore (a Singapore company or VCC) and you want a formal MAS award and the credibility that comes with onshore substance. 13D suits genuinely offshore vehicles managed from Singapore.
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.