Family office hiring under 13O / 13U / GIP: Documents...

Family office hiring under 13O / 13U / GIP sits at the intersection of MAS fund tax incentive conditions and MOM work pass rules: a single-family office must meet minimum local headcount and business spending conditions to keep its 13O or 13U exemption, and principals applying under the Global Investor Programme (GIP) face separate residency and investment requirements entirely.

What family office hiring under these schemes means

Section 13O and Section 13U of the Income Tax Act 1947 provide tax exemption on specified income for qualifying funds managed by a Singapore-based fund manager, and the Monetary Authority of Singapore (MAS) attaches conditions to that exemption, including a minimum number of local investment professionals employed by the family office and a minimum level of local business spending. Hiring under these schemes is therefore not optional headcount growth; it is a compliance requirement that keeps the underlying tax exemption alive. The Global Investor Programme, administered by the Economic Development Board (EDB), runs on a separate track: it grants Singapore Permanent Residence to qualifying investors, and family office principals often pursue GIP alongside setting up their 13O or 13U vehicle, even though the two schemes have distinct approval bodies and criteria.

Who this guide is for

This guide is for family office principals, COOs and HR advisers setting up or scaling a single-family office in Singapore under the 13O or 13U scheme, and for long-term residents and principals considering the Global Investor Programme as a route to Permanent Residence alongside their family office structure.

Eligibility and documents required

For 13O (the scheme for smaller, typically onshore funds), current MAS conditions require the fund to hold a minimum of S$5 million in assets under management and employ at least two investment professionals in Singapore, with MAS increasingly expecting at least one to be a non-family member. For 13U (aimed at larger funds), the minimum asset size rises to S$50 million, with a minimum of three investment professionals expected. Both schemes also carry a minimum local business spending condition, which is tiered by fund size rather than a single flat figure.

Since 15 June 2026, MAS has also moved to a notification-based class exemption model for single family offices operating in Singapore, replacing the prior regime of individual MAS approvals for the licensing exemption itself. This class exemption framework runs alongside, and separately from, the 13O and 13U tax incentive applications: a family office can rely on the notification-based exemption for its licensing position while still applying to MAS for 13O or 13U tax treatment on its investment income. The new framework also introduces a 10 percent equity allowance for non-family key executives and a five-generation cap on beneficiaries for the family office to qualify. Family offices already operating before 15 June 2026 have until 15 June 2027 to transition to the new framework, while any family office formed after 15 June 2026 must comply with it immediately.

Documents typically required for the hiring component of a 13O or 13U application include:

Organisational chart showing the investment team, their roles and reporting lines
CVs and relevant qualifications for each investment professional, demonstrating genuine investment expertise rather than administrative functions
Employment contracts or offer letters evidencing Singapore-based, substantively full-time roles
CPF contribution records once staff are onboarded, used by MAS to evidence genuine local employment
Business spending records, such as office lease, professional fees and salaries, to demonstrate the annual local spending condition is met

For GIP, the principal applicant separately submits to EDB a detailed business track record, an investment plan (commonly into a GIP-approved fund, or a new business set-up, or an EDB-approved family office), and personal documentation including passport, education and net worth evidence. GIP is assessed on the individual, not the fund vehicle, though EDB will look at the credibility of the underlying family office or investment plan the applicant proposes.

Cost and timeline: the numbers

13O minimum fund size: S$5 million, with a minimum of two local investment professionals
13U minimum fund size: S$50 million, with a minimum of three local investment professionals
Minimum annual local business spending: S$200,000 for funds below S$250 million, S$300,000 for funds between S$250 million and S$2 billion, and S$500,000 above S$2 billion
Investment professional qualifying salary for EP purposes: generally at or above the prevailing EP qualifying salary of S$5,600/month, though family office hires are frequently well above this given seniority
GIP minimum investment: from S$10 million under the current framework, into an approved investment option
Processing time for the 13O/13U tax incentive application: commonly 4 to 6 months from a complete submission to MAS
Processing time for GIP: typically 6 to 12 months from application to in-principle approval, depending on due diligence complexity
Transition deadline for the new MAS class exemption framework: 15 June 2027 for family offices already operating before 15 June 2026

Step-by-step process

Structure the family office vehicle and confirm which scheme, 13O or 13U, fits the fund’s intended asset size.
Build the investment team hiring plan to meet the local headcount condition before submitting the tax incentive application.
Submit the 13O or 13U application to MAS with the organisational chart, CVs and business spending plan attached.
In parallel, if the principal is pursuing Permanent Residence, prepare and submit the GIP application to EDB with the investment plan and personal documentation.
Onboard investment professionals with EP applications filed through MOM, ensuring qualifying salaries and COMPASS criteria are met for each hire.
Maintain ongoing compliance: track annual local spending, headcount and CPF contributions to evidence the conditions are being met year over year, not just at approval.

The legal framework

The tax exemption itself sits in Section 13O and Section 13U of the Income Tax Act 1947, administered by MAS under delegated conditions that are reviewed periodically. The hiring of investment professionals and support staff is then governed by the Employment of Foreign Manpower Act for any foreign hires requiring a work pass, and by the Employment Act 1968 for the underlying employment relationship once staff are onboarded. Where a principal or investment professional is not yet a citizen or PR, the Immigration Act, administered by ICA, governs their entry and stay in Singapore, separately from both the MAS tax conditions and the GIP residency assessment run by EDB. Because four different frameworks intersect (MAS tax conditions, MOM work pass rules, the Employment Act, and EDB’s GIP criteria) family offices should treat hiring as a coordinated compliance exercise rather than a series of independent HR decisions.

Worked example: staffing a new 13U family office

Consider a family setting up a new single-family office with S$60 million in assets under management, targeting 13U status. The fund exceeds the S$50 million minimum, so the family now needs to build an investment team of at least three professionals based in Singapore. A realistic staffing plan might include a chief investment officer hired on an EP at S$15,000 a month, an investment analyst at S$8,000 a month, and a risk and operations lead at S$9,000 a month, with at least one of these three being a non-family hire to strengthen the application. Local business spending for a fund of this size sits in the S$300,000 band (between S$250 million and S$2 billion), which in practice is easily covered by salaries, office lease and professional fees once the team is in place, but should still be tracked explicitly rather than assumed. Because the office was formed after 15 June 2026, it must comply with the new MAS class exemption notification framework from day one, in addition to filing its 13U tax incentive application.

How the new class exemption framework changes hiring practice

Before 15 June 2026, a single-family office generally needed individual MAS approval to operate under a licensing exemption, with the hiring plan assessed as part of that approval. Under the notification-based class exemption model now in place, the office self-assesses against the published conditions, including the local headcount and spending requirements, and notifies MAS rather than awaiting a bespoke approval. This shifts more of the compliance burden onto the family office itself: getting the investment professional headcount and documentation right at the point of notification matters more, not less, because there is no individual MAS review to catch a weak application before it takes effect. The 10 percent equity allowance for non-family key executives is a further hiring-relevant change, since it gives family offices a concrete tool to attract senior non-family investment talent without diluting family control below a workable threshold.

Common mistakes and gotchas

The most common error is hiring administrative or family-support staff and counting them toward the investment professional headcount condition; MAS expects genuine investment expertise in these roles, and a poorly justified headcount can jeopardise the tax exemption on review. A second mistake is underestimating the local business spending threshold, particularly in the first year when set-up costs are front-loaded but may not all count toward the recurring spending condition. A third is treating GIP and the 13O/13U tax incentive as a single application: they are assessed by different bodies (EDB and MAS respectively) on different criteria, and approval of one does not guarantee approval of the other. Family offices should also budget for the ongoing nature of these conditions: unlike a one-off licence, 13O and 13U status depends on meeting headcount and spending conditions every year, and a shortfall can put the exemption at risk on renewal.

FAQs

What is the minimum local headcount for a 13O family office?

Typically at least two investment professionals based in Singapore, with MAS increasingly expecting at least one to be a non-family member in recent applications.

Is GIP the same application as the 13O or 13U tax incentive?

No. GIP is a Permanent Residence scheme administered by EDB and assessed on the individual principal; 13O and 13U are tax exemption schemes administered by MAS and assessed on the fund vehicle and its local hiring and spending.

Can family members count toward the investment professional headcount?

They can in principle, but MAS has increasingly expected genuine investment expertise and, in many recent approvals, at least one non-family investment professional, so relying solely on family members carries approval risk.

How long does the hiring and application process typically take?

Budget 4 to 6 months for the 13O/13U tax incentive application once the investment team is in place, and 6 to 12 months for GIP, with both processes able to run in parallel rather than sequentially.

What happens if the local spending or headcount condition is not met in a later year?

MAS conditions are ongoing, not one-off, and a shortfall can put the tax exemption at risk, which is why family offices should track compliance annually rather than only at initial approval.

Related guides

For the broader structuring context around family office vehicles, see our guide on Private Trust Company (PTC) setup, which many family offices use alongside a 13O or 13U structure for succession planning. Principals working through the Permanent Residence and citizenship pathway alongside GIP may also find our guide on PR reapplication after losing status through a lapsed Re-Entry Permit useful background on maintaining PR status once obtained. For the corporate services side of setting up the family office entity itself, our sister site’s guide on nominee director services for foreigners covers a structuring point that frequently comes up for overseas principals.

For authoritative source material, consult the Immigration and Checkpoints Authority for entry and residency matters, the Economic Development Board for the Global Investor Programme, and the Ministry of Manpower for work pass rules affecting investment professionals.

Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email [email protected]. Little Big Employment Agency (EA Licence 19C9790) works with a panel of corporate and employment law firms; this article is general information, not legal advice.