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:-

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