On 31 July 2026, MAS issued a circular revising the conditions for funds under Singapore's fund tax incentive schemes, with most changes taking effect from 1 August 2026. For single family offices using the section 13O and 13U schemes, the direction is clear. There are fewer hurdles at the start, more flexibility in how a family invests, and more weight on what the fund looks like at the end of each year.
We think this is a sensible recalibration. The 2023 revisions raised the bar for family offices, with more investment professionals, higher local spending and a new capital deployment requirement. Those conditions achieved their aim of bringing real substance to Singapore, but some of them were hard to manage in practice, particularly for mid-sized offices. The new framework keeps the substance and removes much of the friction.
What has changed
| Condition | Before | From 1 August 2026 |
|---|---|---|
| Minimum assets in designated investments | S$20 million for 13O, S$50 million for 13U, maintained throughout the incentive period | Same amounts, tested at application and at the end of each basis period |
| Investment professionals | Two for 13O and three for 13U, all in place at application | One of them can be hired after approval, by the end of the first basis period. At least one must still be a non-family member |
| Local business spending | S$200,000 to S$1 million, stepping up at S$50 million and S$100 million of assets | S$200,000 below S$250 million, S$500,000 from S$250 million, S$1 million from S$2 billion |
| Capital deployment | The lower of 10% of assets or S$10 million, across a wider set of categories | Same amount, with fewer, simpler categories. Some Singapore investments, such as Singapore-listed equities, still count double |
| Private banking account | Required under some award conditions | Required for all family office funds, with a three-month grace period from 1 August 2026 (to the end of October 2026) for those newly affected |
| Physical precious metals | Capped at 5% of designated investments | Cap removed |
| Tokenised assets | No express guidance | Tokenised interests in designated investments recognised |
The schemes currently run until 31 December 2029.
Our view on what matters
The spending tiers are the biggest practical change. Under the 2023 framework, a family office with S$120 million under management needed to spend at least S$1 million a year in Singapore. Under the new tiers, the same office needs S$200,000. Many offices will keep spending more because the team requires it, but the incentive no longer forces the decision.
Phased hiring matches how family offices are actually built. Good investment professionals are rarely hired on a timetable set by an application form. Allowing one hire to follow approval removes a common source of delay, though the deadline at the end of the first basis period is firm and worth planning for.
Year-end becomes the moment of truth. Testing assets at the end of each basis period, instead of throughout, reduces day-to-day monitoring. It also concentrates the risk. If assets in designated investments fall below the minimum on the last day of the year, that is the figure that counts. Year-end valuations, particularly of private holdings, now need to be accurate, documented and ready for review.
The private banking account deadline is close. For family office funds newly required to hold one, the grace period ends with October 2026, only weeks away. Opening a private banking account takes time, so this should be the first item on the list.
What we would tell a family office this quarter
- Check the private banking account requirement now, and start the account opening if it applies.
- Work out your new spending tier, and decide whether your current budget is driven by the business or by the old threshold.
- Plan the year-end close early. Agree how each designated investment will be valued, who signs off the figures, and how the capital deployment calculation will be evidenced.
- Keep the evidence in one place. Investment professionals' details, spending records, valuations and bank statements should be ready before the annual declaration is due.
- Confirm your transition position. Existing award holders move to the revised conditions in different ways depending on when their award was granted, so check with your tax adviser which conditions now apply to you.
Where we fit
These changes reduce the effort of qualifying, and increase the importance of getting the year-end figures right. That is where a fund administrator earns its place. Magoran Group prepares year-end NAVs and the supporting schedules that tests like these depend on, so the figures in an annual declaration can be traced back to the books.