Section 13O: Singapore’s resident fund tax exemption

What is Section 13O?

Section 13O (named for the section of the Income Tax Act, and historically called the "Singapore Resident Fund" scheme) exempts the specified income of an approved onshore fund. The fund itself is a Singapore tax resident — a company or VCC — and the exemption flows from MAS approval rather than from the structure. You apply to MAS, MAS issues an award letter, and the exemption holds for the life of the fund as long as conditions are maintained.

Who qualifies for Section 13O?

To qualify, a fund generally needs to be:

• A Singapore-incorporated company or VCC (offshore vehicles look at Section 13D instead; Singapore limited partnerships use Section 13OA);
• Managed by a MAS-licensed or exempt fund manager based in Singapore;
• Confirm the applicable AUM and personnel conditions. The reference thresholds are S$5 million for non-SFO funds and S$20 million for SFO funds, with two qualifying investment professionals. Measurement dates, transition rules and any non-family requirement must be checked for the relevant track;
• Meeting the tiered local business spending requirement.

What are the 13O AUM and headcount numbers?

The S$5 million and S$20 million figures refer to different 13O tracks; they are not interchangeable. Likewise, the requirement for two qualifying investment professionals must be read with the track-specific personnel criteria and transition arrangements. Do not apply the earlier annual AUM test to every fund without checking subsequent amendments and its award terms.

What is the local business spending requirement?

The table retains the published local-spending tier reference. It is not a single schedule for every 13O fund: confirm the applicable track, award date, current tiers and which expenses qualify before preparing a budget.

How do I apply for Section 13O?

13O requires a formal application to MAS before or shortly after the fund begins operating. You submit details of the fund, the manager, the investment professionals and projected AUM and spending. MAS reviews and issues an award letter. We cover the mechanics in how to apply via MAS. Family offices typically run the same playbook — see family office structures.

What other Singapore tax benefits apply?

The income-tax exemption is the headline, but a fund that qualifies for 13O also picks up two further reliefs that matter to a working VCC:

• GST remission for funds. A qualifying fund — a standalone VCC or a sub-fund of an umbrella VCC — is not GST-registered, but can still recover most of the GST it incurs on expenses such as administration, audit, legal and custody. It claims at a fixed recovery rate by filing a quarterly Statement of Claims with IRAS. The remission currently runs to 31 December 2029.
• Favourable stamp-duty treatment of VCC shares. Because a VCC issues and redeems its own shares at net asset value, investors entering and exiting the fund are not making a dutiable share transfer. Stamp duty only arises where shares are cancelled and re-issued to move them from one holder to another — a genuine secondary transfer — which is treated as a 0.2% share transfer under the Stamp Duties Act. For an umbrella VCC, each sub-fund is treated as a separate person for stamp-duty purposes.

Neither relief is unique to 13O — both follow from the VCC being a qualifying Singapore fund — but with the income-tax exemption they are why a VCC is taxed as a fund rather than as an ordinary private limited company.

Frequently asked questions