Fund Tax Incentives
Non-SFO Funds: Section 13O and 13U Requirements
Last updated: November 2026 · Reflects MAS Circular FDD Cir 05/2026
Non-SFO funds are funds managed or advised by a licensed fund management company in Singapore, rather than by a single family office. To qualify for the Section 13O or 13U tax incentive, these funds must meet the economic conditions below.
The requirements below reflect MAS Circular FDD Cir 10/2024 as updated by MAS Circular FDD Cir 05/2026 (31 July 2026), for awards commencing on or after 1 January 2025. Funds with earlier awards may be subject to transitional arrangements. This summary is for general information only and is not tax or legal advice.
Key Requirements
| Requirement | Section 13O / 13OA | Section 13U |
|---|---|---|
| Minimum AUM in designated investments (DI) | S$5 million at the point of application, with a grace period up to the end of the third year of assessment. No annual minimum after that. | S$50 million at the point of application, with no grace period. No annual minimum after that. |
| Investment professionals (IPs) | The Singapore fund manager must employ at least 2 qualifying IPs | The Singapore fund manager must employ at least 3 qualifying IPs |
| Local business spending (LBS) | Tiered by AUM in DI (see below) | Same as 13O |
| Fund manager | Managed or advised by a fund management company in Singapore | Same as 13O |
Local Business Spending
Tiered by AUM in DI at the end of each financial year.
| AUM in DI | Minimum annual LBS |
|---|---|
| Below S$250 million | S$200,000 |
| S$250 million to below S$2 billion | S$300,000 |
| S$2 billion and above | S$500,000 |
Other Points to Note
- AUM in DI may include assets managed on either a discretionary or an advisory basis.
- Closed-end funds, such as private equity and real estate funds, may elect to meet the LBS requirement on a cumulative basis up to the tenth incentive year, with the requirement waived from the eleventh year.
- Non-SFO funds may not hold investments in operating businesses owned, controlled or influenced by the fund's investors or their families.
- The capital deployment requirement that applies to SFO funds does not apply to non-SFO funds.
Source: MAS Circular FDD Cir 05/2026. Please refer to MAS for the full conditions.
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