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ANLIAN GROUP

Services · Family Office · Section 13U

Section 13U — the enhanced family office tier.

Section 13U of the Singapore Income Tax Act is the enhanced family office tax incentive — designed for larger fund vehicles where the 13O thresholds are below the family's actual scale. Like 13O, MAS administers the application and IRAS grants the tax exemption itself. The qualifying conditions are higher: minimum fund size, more qualifying Investment Professionals, higher annual local business spending. Anlian Group provides advisory and application support; investment management itself sits at sister entity Anlian Capital Pte Ltd under MAS Capital Markets Services licence CMS101702 — a separate engagement under a separate regulatory perimeter. ALG is not a fund manager.

Qualifying conditions

  • Minimum fund size — S$50M of qualifying assets serves as the working planning anchor; specific thresholds for SFO applicants are confirmed by MAS on a case-by-case basis at application stage.
  • At least three qualifying Investment Professionals — substantively employed by the Singapore family office. MAS expects a substantive role for each IP, not nominal employment.
  • Annual local business spending — S$0.5M to S$1M annually depending on fund size, on a tier set by MAS.
  • Local investment requirement — same minimum deployment floor framework as 13O (10% of AUM or S$10M, whichever is lower), into eligible Singapore-based investments.
  • Substance and reporting — annual declaration to MAS covering AUM, IP headcount, local business spending, and local investment compliance.

13U suits family offices above S$50M AUM, multi-strategy investment styles, and Option C GIP applications where a parallel 13U is the frequent structural pairing.

What an engagement covers

  1. Pre-incorporation structuring — fund vehicle and family office (manager) entity separated cleanly.
  2. Singapore Pte Ltd incorporation for both entities.
  3. Three (or more) qualifying IP sourcing and onboarding — the longest critical-path item in most engagements, longer than 13O's single-IP requirement.
  4. Corporate banking introduction with a Singapore private banking team.
  5. MAS Tax Incentives Division application packet — AUM substantiation, IP team documentation, local investment plan, business spending plan, source-of-wealth narrative.
  6. Where Option C GIP runs in parallel — coordination of EDB GIP application with the MAS 13U application on a shared timeline.
  7. Ongoing compliance — annual declaration to MAS covering AUM / IP headcount / local business spending / local investment compliance.

Realistic timeline

13U applications run five to seven months from packet submission to MAS approval — longer than 13O because the larger structure invites more diligence on staffing, spending, and the investment plan. Pre-application engagement (incorporation, three-IP team, banking) adds a further three to four months when run in parallel. Where Option C GIP runs alongside, the EDB approval timeline (nine to twelve months from formal submission) becomes the binding constraint on the overall engagement window.

Common confusions worth clarifying

13U is not just "13O at higher numbers". Beyond the thresholds, 13U applications carry more scrutiny on staffing substance (3 IPs each in substantive roles, not 1) and on the local business spending evidence base. The application work is meaningfully longer than a comparable 13O engagement.

13U + Option C GIP is a frequent pairing, not the same thing. Both are EDB- or MAS-administered, both apply to Single Family Offices, both can sit on the same investment vehicle. But they are two separate approvals — Option C GIP is administered by EDB and is about residence; 13U is administered by MAS and is about tax incentive. Two regulators, two timelines, one coordinated engagement.

MAS administers; IRAS grants. Same regulatory split as 13O. The application is processed by the MAS Tax Incentives Division. The tax exemption itself is granted by IRAS under the Income Tax Act. Both regulators see the same documents but operate under different statutory frameworks.

Read more

For the AUM-based decision between 13O and 13U, see 13O vs 13U: Which Singapore Family Office Scheme Fits Your AUM Range?. Parent pillar: Family Office Setup. Sibling page: Section 13O Scheme. For Option C GIP context: Global Investor Programme.

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