Does Anlian Group manage the family office fund directly?

No. Anlian Group provides advisory and application support for the 13O or 13U scheme, including structuring, the MAS application packet, local hire scoping, and ongoing compliance review. Investment management is a regulated activity under MAS rules and is delivered through sister entity Anlian Capital Pte Ltd, which holds the MAS Capital Markets Services license CMS101702.

Can a family hold 13O for two years and migrate to 13U?

Yes, but the migration is a fresh application, not an upgrade in place. Families that anticipate crossing the practical 13U threshold within 18-24 months often find it cleaner to apply for 13U from the start, sized for the AUM trajectory rather than the current snapshot.

How long does the MAS application typically take?

In our recent experience, well-prepared 13O applications reach approval in three to five months from packet submission, depending on MAS load and any source-of-wealth follow-ups. 13U applications run longer — five to seven months is typical — because the larger structure invites more diligence on staffing, spending, and investment plan substantiation.

Is the 10% local investment requirement a hard floor or a target?

The 10% / S$10M is a hard floor at application and an ongoing condition through the incentive period. Funds that drop below the floor due to market value movement are expected to rebalance. MAS reviews ongoing compliance, so falling out of the floor for two consecutive reporting periods is materially riskier than a single-quarter dip.

Do 13O and 13U cover crypto and digital assets?

The Designated Investments definition is set out in the Income Tax Act and supporting subsidiary legislation. Listed equities, debt securities, and many traditional fund interests are clearly within scope; certain digital assets are not. Families with material crypto exposure should structure that portion outside the 13O or 13U fund vehicle and confirm Designated Investment scope at the application stage.

What happens if AUM drops below S$20M after a 13O approval?

A persistent drop below the S$20M floor breaches a scheme condition. MAS in practice gives families a chance to restore AUM (top-up from family principals, repositioning of holdings) before withdrawing the incentive. The family office should document the cause of the drop and the remediation plan in writing as soon as the floor is breached.

Does the family principal need to be Singapore-resident?

The family office (the SFO entity) must be Singapore-incorporated and operating from Singapore, which under ACRA rules requires at least one Singapore-resident director on the SFO entity. The family principals themselves do not need to be Singapore tax-resident, though many relocate at least the primary family member to support substance and to access Singapore PR pathways. Whether the principal personally relocates is a separate decision driven by tax residency optimisation, not by 13O or 13U scheme conditions.

Article

13O vs 13U: Which Singapore Family Office Scheme Fits Your AUM Range?

In one sentence

Section 13O suits S$20M-S$50M AUM single family offices; Section 13U suits S$50M+ with capacity to hire three investment professionals and meet enhanced spending.

Quick answer

Section 13O: minimum S$20M AUM in Designated Investments at application, at least one investment professional, S$10M or 10% of AUM (whichever is lower) deployed locally.
Section 13U: positioned as the enhanced tier for larger funds, with industry practice citing a minimum S$50M fund size, at least three investment professionals, and a higher annual business spending floor.
Both schemes exempt Specified Income from Designated Investments from Singapore tax for the fund vehicle, not the family office.
Both require MAS approval, a private banking account with a MAS-licensed financial institution, and ongoing compliance with the conditions throughout the incentive period.
Choosing wrongly means either over-capitalising for 13U conditions (cost) or hitting 13O ceilings and being forced to migrate (operational disruption).

Why this matters in 2026

Singapore reaffirmed its single family office framework in 2024 after public consultation, and the practical effect since then is that MAS expects substance — local hires, real business spending, deployed local investment — rather than a paper structure.

Two patterns make the 13O-vs-13U choice harder than it used to be. First, families relocating from Hong Kong, the US, and Western Europe arrive with a wider AUM range than the post-2018 wave; some sit comfortably in 13O territory while others are large enough that 13U efficiencies start to matter. Second, MAS's 2024 framework refinements added a 10% cap on AUM attributable to non-family key employees, which interacts with how the family staffs the office and which scheme they qualify for.

Choosing the wrong scheme is correctable but expensive. The cleaner path is to map AUM, family employment plans, and investment style onto the right scheme at application, not to migrate later.

The fundamentals

What Section 13O actually requires

Section 13O exempts Specified Income from Designated Investments from Singapore tax for the fund vehicle managed by the SFO. The headline conditions, per MAS guidance, are:

— Minimum S$20M in Designated Investments at point of application. SFOs applying with S$10M can be granted incentive on condition the fund reaches S$20M within the two-year grace period.

— At least one qualifying investment professional employed by the SFO as portfolio manager, research analyst or trader, earning more than S$3,500 per month and spending more than 50% of working time on the qualifying activity.

— Local investment of at least S$10M or 10% of AUM (whichever is lower) into qualifying local categories, in force for SFO applicants from April 2022.

— A private banking account with a MAS-licensed financial institution at the point of application and throughout the incentive period.

— Capital deployment multipliers of 1.5x or 2x recognition for Singapore listed equities and deeply concessional capital in blended finance structures, in force from 5 July 2023.

13O works for families whose AUM sits in the S$20M-S$50M band and whose investment activity is predominantly passive or single-portfolio-manager-led. The single-IP requirement is the real constraint at the lower bound.

What Section 13U adds — and demands

Section 13U is positioned as the enhanced tier for larger fund vehicles. MAS's public scheme documentation describes 13U as available to fund vehicles managed by Singapore-based fund managers including family offices, on the same Specified Income / Designated Investments exemption mechanic as 13O, but with conditions stepped up to match the larger fund profile.

Industry practice — and most professional advisors will confirm this — places the practical 13U entry point at S$50M minimum fund size, with at least three qualifying investment professionals and a higher annual business spending tier than 13O. Specific thresholds for 13U as applied to a single family office are confirmed by MAS on a case-by-case basis at the application stage rather than published as bright lines. The S$50M / three-IP / higher-spending pattern below is industry advisor consensus for planning purposes; treat it as a starting point for the MAS conversation, not a published rule.

13U is the right call when the family is willing to staff up to a real investment team (not just one portfolio manager), expects to run more than one portfolio strategy, and has the AUM to absorb the higher local spending and hiring obligations without distorting investment economics.

The 10% non-family key employee cap

Following the 2023-2024 consultation on the single family office framework, MAS introduced a 10% cap on the percentage of AUM that can be attributed to non-family key employees. This matters most for families considering 13U, where the larger AUM and three-IP staffing requirement raises the chance that a senior non-family hire holds a meaningful equity-style stake.

The cap interacts with how the family compensates senior investment staff (carry pools, equity participation in the SFO entity, side-by-side investment vehicles), and a poorly structured compensation plan can put the entire incentive at risk. Families running 13O with a single IP usually do not approach this cap; families considering 13U with multiple senior hires should design compensation around it from day one.

	Section 13O	Section 13U
Minimum fund AUM at application	S$20M (S$10M with 2-year ramp permitted)	S$50M (industry practice; confirmed case-by-case with MAS)
Minimum investment professionals	1 (qualifying portfolio manager / research analyst / trader)	3 (industry practice)
IP salary floor	Greater than S$3,500/month, >50% time on qualifying activity	Same minimum criteria; higher in practice for senior team
Local investment requirement	10% of AUM or S$10M, whichever is lower	10% of AUM or S$10M, whichever is lower
Banking	Private banking account with MAS-licensed FI required	Same
Multipliers (SG listed + blended finance)	1.5x or 2x recognition since 5 July 2023	Same multipliers apply
Tax exemption mechanic	Specified Income from Designated Investments exempt for the fund vehicle	Same mechanic, enhanced tier
Approval body	MAS	MAS
Typical AUM band where this is the right call	S$20M-S$50M	S$50M+
Best fit profile	Single-portfolio family, passive long-term holdings, lean staffing	Multi-strategy family, capacity for full investment team, larger local footprint

Common pitfalls

Applying for 13O at exactly S$20M with no headroom
Applying right at the S$20M floor leaves no buffer for market drawdowns. A 15-20% portfolio decline in year one can push AUM under S$20M and trigger compliance review. Build in a 25-30% AUM buffer above the floor at application.
Underestimating the single IP requirement at 13O
The portfolio manager / research analyst / trader hire is not a back-office headcount. The person must earn more than S$3,500 per month and spend more than 50% of working hours on qualifying activity, documented in the SFO's job records. A part-time CIO who also runs an external fund will not qualify.
Treating 13U thresholds as published bright lines
MAS does not publish 13U thresholds for SFO applicants as fixed numbers in the same way 13O's S$20M / one IP appears in scheme documentation. The S$50M / three IP / higher spending pattern is industry practice, confirmed by MAS at the application stage. Plan with professional advice rather than the lowest figure cited online.
Confusing the 13O/13U fund tax exemption with personal tax exemption for family principals
The exemption applies to the fund vehicle on Specified Income from Designated Investments. Family principals remain personally subject to Singapore tax on any income they personally derive (employment income, distributions characterised as dividends or salary). The scheme is not a personal tax shelter.
Paying the local investment requirement only at the threshold
Meeting exactly 10% of AUM or S$10M (whichever is lower) on application day is not the same as maintaining it. The local deployment is an ongoing condition. Families who deployed at the floor and let market value drift should rebalance quarterly, not annually.

Frequently asked questions

Does Anlian Group manage the family office fund directly?: No. Anlian Group provides advisory and application support for the 13O or 13U scheme, including structuring, the MAS application packet, local hire scoping, and ongoing compliance review. Investment management is a regulated activity under MAS rules and is delivered through sister entity Anlian Capital Pte Ltd, which holds the MAS Capital Markets Services license CMS101702.
Can a family hold 13O for two years and migrate to 13U?: Yes, but the migration is a fresh application, not an upgrade in place. Families that anticipate crossing the practical 13U threshold within 18-24 months often find it cleaner to apply for 13U from the start, sized for the AUM trajectory rather than the current snapshot.
How long does the MAS application typically take?: In our recent experience, well-prepared 13O applications reach approval in three to five months from packet submission, depending on MAS load and any source-of-wealth follow-ups. 13U applications run longer — five to seven months is typical — because the larger structure invites more diligence on staffing, spending, and investment plan substantiation.
Is the 10% local investment requirement a hard floor or a target?: The 10% / S$10M is a hard floor at application and an ongoing condition through the incentive period. Funds that drop below the floor due to market value movement are expected to rebalance. MAS reviews ongoing compliance, so falling out of the floor for two consecutive reporting periods is materially riskier than a single-quarter dip.
Do 13O and 13U cover crypto and digital assets?: The Designated Investments definition is set out in the Income Tax Act and supporting subsidiary legislation. Listed equities, debt securities, and many traditional fund interests are clearly within scope; certain digital assets are not. Families with material crypto exposure should structure that portion outside the 13O or 13U fund vehicle and confirm Designated Investment scope at the application stage.
What happens if AUM drops below S$20M after a 13O approval?: A persistent drop below the S$20M floor breaches a scheme condition. MAS in practice gives families a chance to restore AUM (top-up from family principals, repositioning of holdings) before withdrawing the incentive. The family office should document the cause of the drop and the remediation plan in writing as soon as the floor is breached.
Does the family principal need to be Singapore-resident?: The family office (the SFO entity) must be Singapore-incorporated and operating from Singapore, which under ACRA rules requires at least one Singapore-resident director on the SFO entity. The family principals themselves do not need to be Singapore tax-resident, though many relocate at least the primary family member to support substance and to access Singapore PR pathways. Whether the principal personally relocates is a separate decision driven by tax residency optimisation, not by 13O or 13U scheme conditions.

How Anlian Group helps

Anlian Group has supported family offices through both schemes. We start every engagement with a structured assessment — what the family's AUM trajectory looks like, what staffing the family is willing to commit to, what investment style fits the principals' temperament — and only then map onto 13O or 13U. We prepare the MAS application packet, run the local hire scoping, and stay engaged through the ongoing reporting. Investment management itself is delivered through our sister entity Anlian Capital Pte Ltd, which holds the relevant MAS license; that line stays clean.

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