Comparison guide

13O vs 13U Singapore: which family office route fits better?

Choosing between Section 13O and Section 13U is not simply about which tax incentive is “better.”
The right route depends on the fund vehicle, assets under management, investment team, operating structure and the conditions the fund is prepared to maintain each year.

Both schemes can provide Singapore tax exemption for qualifying fund income, subject to their respective conditions. The main differences are in the structure and ongoing requirements.

13O and 13U at a glance

Current requirements can be subject to transition periods for existing incentive holders, so the fund's MAS approval letter and latest applicable conditions should always be checked.

The fund size difference is important

Under the current framework, Section 13O has a substantially lower minimum fund size than Section 13U.

A Section 13O fund generally needs at least S$5 million of AUM invested in designated investments at the end of the financial year. Section 13U generally requires at least S$50 million at the point of application and at the end of each financial year.

This is one reason Section 13U is more commonly associated with larger fund structures.

The investment team requirement is different

The current framework also differs in the number of investment professionals required.

Section 13O generally requires at least two investment professionals, while Section 13U generally requires at least three.

Investment professionals generally include portfolio managers, research analysts and traders who meet the relevant employment and qualifying activity conditions.

Local business spending applies to both

Both schemes are subject to local business spending requirements under the current framework.

The current minimum annual amounts are generally:
- AUM below S$250 million: S$200,000
- AUM from S$250 million to below S$2 billion: S$300,000
- AUM of S$2 billion or more: S$500,000

Local business spending generally refers to relevant expenses paid to contracting parties in Singapore.

13O is not simply the “small” version of 13U

The decision should not be based only on fund size.

Other factors include:
- the legal form and location of the fund vehicle
- Singapore tax residency requirements
- the fund management arrangement
- the number of investment professionals available
- the expected AUM
- local business spending
- investment strategy
- future expansion or restructuring plans

What should a family office compare before choosing?

Before deciding between 13O and 13U, consider:
- whether the proposed fund vehicle meets the structural requirements
- whether the minimum AUM can be maintained
- whether the investment professional requirement is practical
- whether local spending requirements can be met consistently
- whether the fund administrator and management arrangements are in place
- whether the family expects the fund to grow or change structure later

A tax incentive only works properly if the fund can continue meeting its conditions after approval.

The annual compliance work still matters

Whichever route is used, the finance function should keep enough information to support the ongoing incentive conditions.

This can include:
- updated accounts and reconciliations
- AUM schedules
- investment records
- local business spending tracking
- investment professional information
- year-end tax schedules
- information needed for the MAS annual declaration

Related family office guides

If you already operate a Section 13O structure, read 13O tax filing Singapore and 13O annual compliance support Singapore .

For broader support, visit family office accounting and compliance Singapore .