Section 13O vs 13U: Singapore Fund Tax Incentives Explained

Q: What is the difference between 13O and 13U?

13O is the onshore fund scheme, with a S$20M AUM floor, two investment professionals and a Singapore company or VCC vehicle. 13U is the enhanced tier, with a S$50M floor, three professionals and flexibility to use offshore vehicles and umbrella VCCs.

Q: Is a VCC the same as 13O or 13U?

No. A VCC is a legal structure. 13O and 13U are tax incentives applied for separately, and can be held by a fund that uses a VCC.

Q: What counts as an investment professional?

A portfolio manager, research analyst or trader earning more than S$3,500 a month and spending more than 50% of their time on the qualifying activity.

Q: Does the incentive need to be renewed?

Yes. The incentive runs for a fixed period and is renewed periodically, with the conditions re-evidenced at renewal. Confirm the current cadence with MAS.

By aama.io Fund Operations Team · Last reviewed 2 October 2026

Sections 13O and 13U of the Singapore Income Tax Act are tax incentive schemes that exempt qualifying income of a fund managed from Singapore. 13O is the onshore scheme, usually for single family offices from S$20M AUM; 13U is the enhanced tier for larger or multi-vehicle structures from S$50M AUM.

Sourced information — it can change

This page is compiled from public sources (listed at the bottom) and last reviewed on 2 October 2026. Regulations, thresholds, fees and market practice change, so it may not reflect the latest position. Check with MAS, IRAS and a licensed tax adviser before acting.

Key facts

Legislation	Income Tax Act 1947, sections 13O and 13U
Administered by	MAS (approval) and IRAS (tax)
Minimum AUM	13O: S$20M. 13U: S$50M
Investment professionals	13O: at least 2. 13U: at least 3
Fund vehicle	13O: Singapore company or VCC. 13U: onshore or offshore, including umbrella VCCs
Local business spending	Tiered by AUM: S$200,000 (under S$50M), S$500,000 (S$50M–100M), S$1,000,000 (over S$100M) a year
Singapore investment	At least 10% of AUM or S$10M, whichever is lower

How it works

Pick the scheme. 13O suits a single family office or smaller fund. 13U suits larger or multi-fund structures that need offshore vehicles or an umbrella VCC with several sub-funds.
Set up the vehicle and substance. The fund administration company must operate from physical commercial premises in Singapore. Virtual offices are not accepted. 13O also requires a Singapore-based administrator.
Hire the investment professionals. An investment professional is a portfolio manager, research analyst or trader earning more than S$3,500 a month and spending more than 50% of their time on the qualifying activity.
Meet spending and investment tests. Commit to the annual local business spending tier for your AUM, and keep the Singapore investment requirement met at any one time, including during the application.
Apply, then re-earn it every year. Approval is not permanent. Conditions such as AUM, headcount, local spend, capital deployment and the UBO register are tested on an ongoing basis, and the incentive is renewed periodically.

Worked example: A S$60M single family office

A family office with S$60M in AUM wants to apply. Work out which scheme and what the spending and investment tests require.

AUM meets 13O floor (S$20M)?	Yes
AUM meets 13U floor (S$50M)?	Yes
Local business spending tier (S$50M–100M)	S$500,000 a year
10% of AUM (10% × S$60M)	S$6M
Singapore investment required (lower of S$6M and S$10M)	S$6M
Investment professionals needed	2 for 13O, 3 for 13U

Both schemes are open at this size. If the family office holds a single Singapore vehicle, 13O needs one fewer professional. If it needs offshore vehicles or several sub-funds, 13U is the route.

Common mistakes

Treating the VCC as the tax exemption. The incentive is applied for separately.
Counting a virtual office as substance. MAS requires physical commercial premises.
Testing conditions once a year. Spending and Singapore-investment minimums move every month.
Forgetting the UBO register, which must be kept current within days of an ownership change, not on an annual cycle.

The Singapore and APAC angle

This is a Singapore-only regime, and thresholds and renewal terms are revised from time to time, so confirm the current conditions with MAS and IRAS before applying. The operational point most often missed is that approval is the start: the spending, investment, headcount and UBO conditions are tested continuously, which is a fund-accounting and compliance-tracking job, not a one-off filing.

Frequently asked questions

What is the difference between 13O and 13U?

Is a VCC the same as 13O or 13U?

What counts as an investment professional?

Does the incentive need to be renewed?

Free tools

MAS Fund Management Licence Estimator (CMS, RFMC, Family Office)Umbrella vs Standalone VCC Structure Comparator Carried Interest Tax Estimator (Singapore, US, UK)

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Go deeper

Section 13O vs 13U (2026)How to Set Up a VCC in Singapore (2026)Singapore Family Office Compliance in 2026: CDR, LBS, UBO Register and VCC Sub-Fund Rules Explained

Related terms

Variable Capital Company (VCC)

A Variable Capital Company (VCC) is a Singapore corporate fund structure, available since January 2020, that can hold a single fund or an umbrella of ring-fenced sub-funds. It issues and redeems shares at net asset value without a capital-reduction process, and must be managed by an MAS-regulated fund manager.

Fund Administrator

A fund administrator is the firm, or in-house team, that runs a fund's back office: calculating NAV, keeping the books, processing capital calls and distributions, maintaining investor records and producing reports. It is distinct from the fund manager, which makes the investment decisions.

Management Fee

A management fee is the annual fee a fund pays its manager to cover operating costs, regardless of performance. In private equity and venture capital it is commonly around 2% a year, charged on committed capital during the investment period and on invested capital afterwards, and it is funded through capital calls.

Sources

MAS — Tax incentive schemes for fund management IRAS — Fund tax incentives

General information, not tax, legal, accounting or investment advice. This content is sourced from the references above and from public regulatory material, and it can become outdated. Always confirm the current position with MAS, IRAS and a licensed tax adviser, and take professional advice for your specific situation, before relying on it.