Note: Local investments refer to (i) equities, REITS or Business Trusts listed on Singapore-approved exchanges .  (ii) qualifying debt securities, (iii) funds distributed by Singapore-licensed/registered fund managers or financial institutions, (iv) private equity investments into non-listed Singapore-based incorporated companies (eg. Start-ups) with operating business(es) in Singapore.

The recent requirements make SFO’s to –

  1. Uplifting the standards of SFO in anticipation of upcoming demands and challenges.
  2. Deepening and broadening of skillsets within SFOs.
  3. Sufficient resources for sustainability and robust operations of SFOs.

Implications of recent regulatory developments – MAS (Application Criteria and Process for Family Offices (updated 01.12. 2022)

Can a fund invest in the UBO’s operating business?

  • Fund vehicles are not considered to be holding controlling stakes in related operating entities:
  1. fund vehicle does not hold >25% of total outstanding shares of the operating business permanently.
  2. UBO/family’s shares of the operating businesses do not take up >50% of the total AUM across all fund vehicles owned by the UBO
  3. Fund vehicles, on average, meet AUM requirements after excluding shares of the family’s operating businesses, per fund vehicle.
  4. The fund vehicle is not required to consolidate the results of the operating businesses in its accounts; and
  5. The fund vehicle is not liable to any top-up tax imposed by any jurisdiction as a response to tax exemption enjoyed by the fund vehicle

Exchange of information is extending to CRYPTO – ASSETS

The OECD has recently released a public consultation on Crypto-Asset Reporting Framework and amendments to CRS

Amongst the proposals, the OECD is developing a new global tax transparency framework which provides for the automatic exchange of tax information on transactions in cyrpto-assets in a standardized manner

What does it entail?

  • The definition of cyrpto-asset holdings is wide, covering not only crypto-currencies but also NFTs
  • Once implemented, crypto-assets holdings would be subject to similar reporting obligations like CRS
  • Crypto-service providers are intermediaries would have to be mindful of additional reporting obligations
  • Crypto-service providers would also be require additional information from users.
  • Existing FIs that deal with crypto-assets may also have additional requirements to implement new reporting frameworks for crypto-assets reporting?


  • The authorities have access to greater amounts of data on financial assets and business assets with more effective technology and tools, leading to greater scrutiny by home country tax authority.
  • With data collection mechanisms in place, tax authorities are better equipped
  • Initiatives such as BEP 2.0 leverages off the data pools amassed from CRS and CbC reporting
  • Understand their “tax residency” position
  • Familiarize with reporting obligations (e.g., whether the reporting for FATCA and CRS is done via external financial institutions or through the family’s owns structures)
  • Have handle risks of complex structures
  • Proper structing of offshore investments or operations
  • Need to periodically review offshore structures
  • Where restructuring is required , seek legal and tax advice
  • Supporting documentation must be maintained for all offshore structures in anticipation of queries from authorities
  • Families with business assets and with shares in global MNEs should align CRS with Cbc reporting

Singapore-based SFOs : Entering a new era – MAS circular dated 19-09-2022

Family refer to individuals who are lineal descendants from a single ancestor, as well as the spouses, ex-spouses, adopted children and stepchildren of these individuals

  1. To be an exempt FMC that manages assets for or on behalf of the family(ies); and
  2. Wholly owned or controlled by members of the same family(ies)

SFO also needs to issue annual statement to its investors (for 13D/O funds)

FAQs and Clarifications

Sub-delegation arrangements

Singapore-based FMC must:-



This is a presentation on Singapore’s Variable Capital Company(“VCC”) and is general in nature.
Singapore’s VCC is used as an “investment fund vehicle” for both, open ended and close ended fund structures.
VCC is a corporate entity which is established in Singapore under the Variable Capital Companies Act 2018 (“VCC Act”). It is an investment vehicle or investment entity with corporate identity, The approval for incorporating or registering a VCC is granted by the ACRA, upon the applicant meeting prescribed requirements under the VCC Act and regulations thereto.

VCC being as asset and investment holding entity, is used for investment management and wealth management activities. VCC is required to appoint a Singapore based licenced/registered Fund Management Company as its Manager.

It is established in Singapore by parties such as fund managers, private banks, wealth managers, ultra HNIs, Single Family Offices, Insurance Companies and Asset Allocators
On 15th January 2020 there were 20 VCCs in Singapore, which came through the VCC pilot programme. The number of VCCs as of 15 July 2021 is 330


1. As highlighted, “VCC” stands for Variable Capital Company.
2. VCC is a type of “company” to hold asset and investment for carrying out investment management and wealth management activities.
3. VCC has to be managed by a licenced manager or a registered manager or a manager who is exempted or approved by Monetary Authority of Singapore (MAS) from the requirements of holding fund management licence.
4. Tax incentives are available in Singapore for VCCs (example: Sec 13R, Sec 13X, Sec 13H)
5. VCC regime is an effort of Singapore Government to enable domiciliation of investment and asset holding entity in Singapore, through a corporate entity having variable capital structure.
6. Standalone VCC versus Umbrella VCC – will define the structure being a single fund entity or a multiple fund entity



1. VCC is specifically created for wealth management and investment management activities.
2. It provides flexibility to issue and redeem its shares, with operational ease.
3. VCC can pay dividends out of capital, which gives flexibility to Fund Managers to meet such obligations.
4. VCC’s capital is flexible (unlike a private limited company having fixed capital)
• Management Shares carrying voting rights (no dividend rights); and
• Participating Shares carrying NO voting rights (redeemable, eligible for dividends, upon declaration and other economic benefits)
5. Provides continuity, since VCC is a corporate entity (unlike a non-corporate investment vehicle)
6. Tax/financial incentives are available, subject to meeting requirements (Sec 13R, Sec 13X, Sec 13H)
7. Confidentiality – VCC’s Constitution document, Annual filings, Register of Shareholders of a VCC is not available to public or 3rd parties.
8. VCC can obtain Certificate of Residence (COR) from IRAS, in its own name, unlike a unit trust fund.
9. VCC, if structured well, it can be used as a legal entity for inter-generation wealth transfer.


1) VCC has to be established in Singapore under the VCC Act and Regulations thereto.
2) Submission of prescribed application and requisite declarations are made to ACRA, for incorporation of the VCC
3) VCC’s capital will be variable in nature, resulting in paid capital equals NAV, at a given point in time.
4) Assets and Liabilities of each sub fund has to be segregated, accounted for separately, ring fenced and accounted for at fair value.
5) Mandatory appointment of Director(s), VCC Manager, Company Secretary and Auditor.
6) Necessary to appoint a fund administrator to perform fund accounting, NAV computation and as appropriate to carry out registrar and transfer agency services.
7) Custodian appointment becomes essential when the VCC is investing in listed, traded or quoted securities.
8) AML and CFT guidelines of MAS are applicable to VCC.
9) Appropriate governance framework should be created for the day-to-day operations of the VCC. (This is critical for both VCC Sponsor and VCC Manager)




1. How to structure a VCC?
It depends on several parameters and is a case specific matter. Accordingly cost parameters will vary.
2. Timeline for VCC set up:
Step 1: Name approval
Step 2: Incorporation of VCC
Step 3: Registration of one or more sub-fund(s) of the VCC
3. NS Global Consultants Pte Ltd, Singapore, the consulting arm of Natarajan & Swaminathan Chartered Accountants of Singapore, will function as the Project Manager in Singapore for setting up VCC in Singapore



  • The government is trying to drive money into local
  • Influx of wealth has pushed up property and car prices

(The central business district (CBD) of Singapore. Photographer: Lauryn Ishak/Bloomberg)

By Lulu Yilun Chen and Chanyaporn Chanjaroen
2 March 2023 at 1:35 pm SGT (Updated on2 March 2023 at 2:24 pm SGT)

Singapore is increasing the threshold for global investors seeking permanentresident status in an attempt to create more jobs and benefit locals due to an influx of wealth. Applicants will need at least S$10 million ($7.4 million) in a business or S$25 million in an approved fund, the Singapore Economic Development Board said in a statement Thursday. For those establishing family offices, at least S$50 million must be deployed and maintained in four government-designated investment categories.

That compares with a previous requirement of a S$2.5 million investment in a business entity, fund or Singapore-based single family office. The changes take effect from March 15. Singapore is tackling a perceived growing wealth gap brought on in part by the arrival of rich families from overseas. The country’s infrastructure and stability has attracted a growing number of ultra-wealthy individuals, contributing to a spike in costs for everything from luxury cars to golf club memberships and condominiums.

The government is fine-tuning its policies by encouraging more local jobs and investment in the city-state’s stock exchange and funds. It announced a tax hike on higher-value property and luxury cars in February. The investment program refinement will “encourage the growth of businesses and capital accumulated in Singapore,” Desmond Teo, EY Asean private tax leader said in a statement, adding that two winners will be the country’s asset management industry and companies that will receive funding.

Luring Talent
The Global Investor Programme was introduced in 2004 to attract the world’s wealthiest people and provides a route to permanent residency. About 200 permanent residencies were granted from 2020 to 2022. The design has also brought in at least S$5.5 billion in investments and created more than 24,000
jobs. About S$1.62 billion was injected into approved funds, of which 57% was invested in Singapore-based companies.

The city-state was expected to get around 2,800 high-net-worth individuals in 2022 alone, according to residence and citizenship planning provider Henley & Partners. The firm estimates that 249,800 residents there have a net worth of at least $1 million, making it the world’s fifth wealthiest city.

Here’s a breakdown of the pathways available:
Option A
• Invest at least S$10 million, inclusive of existing paid-up capital, in a new business entity or existing business operation in Singapore
• Hire at least 30 employees, at least half of whom must be Singapore citizens and 10 of whom must be new employees, to be eligible for the Re-entry Permit Renewal after the initial five-year period

Option B
• Applicants must invest S$25 million in a Global Investor Programme-select fund

Option C
• Requirement to establish a Singapore-based single family office with at least S$200 million in assets under management
• At least S$50 million must be deployed and maintained in these categories including companies listed on local exchanges, qualifying debt securities, funds distributed by approved Singapore-licensed managers; or private equity injection into non-listed, Singapore-based businesses.

(Updates with analyst comments throughout)
Courtesy : The Straitstimes – Singapore dated 03.03.2023


New CA Course from May 2024-ICAI-ISCA one pager for ICAI Singapore Chapter

Ahmedabad:  The Institute of Chartered Accountants of India (ICAI) will implement its new course structure from May 2024, a statement from ICAI said on Tuesday.

The statement quoting newly elected national president of ICAI, Aniket Talati, said that the institute has also signed 16 memorandums of understanding with various international organizations including the Institute of Chartered Accountants in England and Wales (ICAEW).Under the New Education Policy, students studying in the CA foundation course will have four question papers while those in intermediate and final courses will have six question papers compared to eight papers earlier.

Earlier, CA students had to undertake articleship for a three-year period which has now been reduced to two.The statement said that the new structure has been sent for approval to the Union government and will be implemented from May 2024.The agreement with the ICAEW, which has been approved by the Union Government, will allow members of ICAI to be eligible for membership of ICAEW in the UK once they take two examinations, the statement said.

The institute also entered into an agreement with the Institute of Singapore Chartered Accountants (ISCA) under which ICAI members residing in Singapore for a minimum duration of six months will get te ISCA membership.The statement also said that ICAI has set up the Institute of Social Auditors of India (ISAI) under SEBI’s amendment in regulations.  The ISAI will prepare social auditor.

Talalti siad that from April 1, 2023, CA firms auditing banking and insurance firms will have to get their audit quality checked by ICAI-appointed reviewers. The ICAI will also set up career counselling centers and reading facilites in 700 districts across the country to guide students.

Restructuring Schemes – Customised (ESS-C)

Small firms to get help with debt restructuring under new schemes
The Law Ministry earlier, had introduced several measures due to Covid-19
pandemic to alleviate the impact of the crisis on business, including a moratorium on legal action over rents and contracts and raising thresholds for bankruptcy and insolvency proceedings. Small firms in financial distress due to Covid-19 will receive help from two new schemes launched on 5th October 2020 – as concerns grow that companies in badly hit industries may be plunged into bankruptcy once earlier support measures come to an end.

The Sole Proprietors and Partnerships scheme
The Association of Banks in Singapore (ABS) aims to complement this by focusing on business that are struggling to service loan commitments but are likely to recover given time and revised repayment terms. It was developed with the support of several ABS member banks, the Monetary Authority of Singapore and Enterprise Singapore. The scheme will allow businesses to work with Credit Counselling Singapore, a non-profit organization, to help restructure unsecured debt owed to 17 participating lenders, including all the main banks here. Firm can work to words securing lower monthly installment payments for unsecured borrowing by extending the loan repayment period up to a maximum of eight years. Interest rates for the restructure debt will be based on the loan’s original contractual terms, subject to a maximum of 7 percent a year. A firm can qualify if its total unsecured debt does not exceed $1 million and it owes unsecured debt to two or more of the participating lenders. Approval will be at the sole discretion of the lenders (Banks).

The extended Support Scheme – Customised (ESS-C)
Customised, is available to SMEs with viable businesses. It has been devised with the support of the Finance Houses Association of Singapore and led by United Overseas Bank and other major banks to help restructure a firm’s credit facilities across multiple banks and finance companies. The intent is to facilitate a more holistic restructuring of an SME’s loans compared to if the SME had to approach its lenders individually. SMEs have already looked at bringing down costs since the coronavirus hit eight months ago. For those who are looking to soldier on, the extra help in access to capital.The schemes would help companies wind down their businesses that may longer be viable.More information on the SPP scheme will be available from Credit Counselling Singapore (CCS) and information on the ESS-C will be provided on the Association of banks in Singapore website.