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Singapore Tax Frameworks: What’s the Difference?
February 10, 2021
WHAT IS IT?:
Section 13X: Enhanced-Tier Fund Tax Incentive Scheme
Creates flexibility for Singapore-based funds to source for investment mandates, with no restrictions or financial penalties on the investments made by Singapore resident persons.
Section 13R: Onshore Fund Tax Incentive Scheme
Designed to facilitate domiciliation of funds into Singapore and to attract the funds of non-Singapore investors.
Section 13H: Tax Incentive
Provides tax exemption for income from funds that meet the scheme’s requirements to invest in unlisted Singapore-based companies (subject to a maximum tenure of 15 years).
THE BREAKDOWN
| Section 13X | Section 13R | Section 13H | |
|---|---|---|---|
| Fund’s Residence | Can be offshore or onshore | Must be a tax resident of Singapore | |
| Fund Expenditure | Minimum S$200k local business spending in a year | Minimum S$200k business spending in a year | Cumulative local business spending (LBS) ≥ S$100,000 multiplied by the incentive tenure |
| Assets Under Management | Minimum S$50mil | No Restrictions | Minimum S$10mil |
| Investors (13X/13R) Investment (13H) | No Restrictions | Must not be 100% owned by SIngapore investors | Invests a certain percentage into unlisted Singapore-based companies by year five of the incentive or by the end of the incentive, whichever is earlier |
| Accepted Fund Legal Structures | Any funds that meet qualifying conditions including Company, Trust, Limited Partnerships, VCCs that are Singapore incorporated or redomiciled into Singapore | Company incorporated in Singapore | Limited Partnership, Company (incorporated in Singapore or elsewhere), and Variable Capital Company (VCC). |
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