Family Office Hiring Under 13O/13U/GIP: Checklist

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.

Family office hiring under 13O / 13U / GIP means matching each hire to two separate rulebooks at once: the Monetary Authority of Singapore’s (MAS) staffing conditions attached to the Section 13O or Section 13U tax exemption, and the individual work pass or Global Investor Programme (GIP) route that lets that person actually live and work in Singapore. Correct as at 2 September 2026.

What family office hiring under 13O / 13U / GIP actually involves

A Singapore family office is not itself a licensed entity , it is a fund management company that applies for tax exemption on its investment income under Section 13O (the onshore fund scheme, formerly 13R) or Section 13U (the enhanced-tier scheme, formerly 13X) of the Income Tax Act 1947. Both schemes carry conditions on assets under management (AUM), local business spending and, critically for this checklist, headcount: MAS requires a minimum number of investment professionals (IPs) employed by the fund vehicle. Separately, the family’s principal (and often their family members) may be seeking Singapore residency through the Global Investor Programme (GIP), which since March 2023 has offered “Option C” , establishing or substantially expanding a single family office , as one of three qualifying investment routes to permanent residence. Hiring, tax structuring and immigration therefore have to be planned as one exercise, not three.

The reason this trips up otherwise well-advised families is that the three regimes are administered by three different bodies with three different tests. MAS looks at the fund vehicle’s AUM, spending and headcount for tax-exemption purposes. The Ministry of Manpower (MOM) looks at each individual hire’s salary, qualifications and COMPASS score for work-pass purposes. The Economic Development Board (EDB) and Immigration and Checkpoints Authority (ICA) look at the principal’s investment commitment and residency case for GIP purposes. A hiring plan that satisfies MAS’s headcount rule can still fail at MOM if the salaries were set too low, and a GIP application can stall at ICA if the underlying 13O/13U position with MAS has not been settled first.

Who this eligibility checklist is for

This guide is for family principals and their advisers who are (a) setting up or already running a 13O or 13U family office in Singapore, (b) hiring investment professionals, portfolio managers, analysts or support staff into that entity, and/or (c) considering the GIP Option C pathway to residency through the family office structure. It is also relevant to HR and compliance staff at multi-family offices and external asset managers who are building out a Singapore-facing team, and to family offices already operating in Singapore who are reviewing their headcount ahead of an annual MAS declaration or a GIP conversion milestone.

Eligibility and requirements checklist

Use this checklist to confirm your family office hiring plan satisfies both the MAS tax-scheme conditions and the relevant work pass or GIP requirements.

Section 13O staffing conditions

Fund vehicle incorporated in Singapore, wholly owned (directly or indirectly) by a single family.
Minimum AUM of S$10 million at the point of application, with a commitment to increase this to S$20 million within a two-year period.
At least two investment professionals employed, of whom at least one is a non-family member.
Each investment professional must earn above the prevailing qualifying salary for a work pass and spend more than 50% of their time on qualifying investment activity.
Minimum local business spending, generally benchmarked to a percentage of AUM, reviewed annually by MAS.

Section 13U staffing conditions

Minimum AUM of S$50 million at the point of application.
At least three investment professionals, of whom at least one is a non-family member.
Higher local business spending threshold than 13O, again reviewed annually.
Fund manager (which may be the family office itself) must hold or be exempt from a capital markets services licence.

GIP Option C overlay (for principals seeking PR)

Establish a new single family office, or substantially expand an existing one, with a minimum of S$200 million in AUM.
Deploy at least S$50 million into qualifying investments in Singapore, such as listed equities, qualifying debt securities or approved property funds.
Employ at least four investment professionals, of whom at least one is a Singapore citizen and one other is either a Singapore citizen or permanent resident.
Alignment with MAS on the 13O/13U tax position is treated as a precondition , applicants who have not settled their tax-scheme headcount and AUM position with MAS typically cannot convert their In-Principle Approval (IPA) to PR.

Work pass eligibility for each hire

Investment professionals and analysts are typically hired on the Employment Pass, subject to the COMPASS points framework and the prevailing qualifying salary.
Family office principals and senior decision-makers may instead qualify for the Personalised Employment Pass or, where they are also pursuing PR, enter via the GIP In-Principle Approval process rather than a standard work pass.
Support and operations staff below the Employment Pass salary threshold are generally not eligible to be counted as investment professionals for 13O/13U purposes, even where they are genuinely employed by the fund vehicle.
Spouses and adult children of the principal who join the family office in a working capacity are assessed as ordinary hires for work-pass purposes , family relationship does not substitute for meeting the salary or COMPASS criteria.

Cost and timeline , the numbers

Budget and sequencing vary by scheme, but as a general benchmark:

13O fund vehicle setup and MAS application: typically S$15,000–S$40,000 in professional fees, plus statutory incorporation costs, with MAS review taking approximately 4–8 weeks once a complete application is lodged.
13U applications, given the higher AUM and licensing overlay, typically take 8–12 weeks for MAS review and involve higher advisory fees, often S$30,000–S$80,000.
Employment Pass applications for investment professionals are decided by MOM within about three weeks of a complete, properly documented submission, with the full process from offer to pass issuance running four to eight weeks.
GIP Option C applications typically take four to six months from submission to In-Principle Approval, with a further period before conversion to permanent residence once the family office and investment conditions are demonstrably met.
Ongoing: 13O and 13U family offices must file annual declarations to MAS confirming continued compliance with headcount, AUM and spending conditions , missing this is one of the most common reasons for losing tax-exempt status.
Recurring hiring cost: budget for Employment Pass application and issuance fees per hire (typically low hundreds of dollars each), plus recruitment and relocation costs that are usually far larger than the government fees themselves.

Step-by-step process

Decide the tax-scheme tier (13O or 13U) based on target AUM and confirm this with MAS or an appointed corporate service provider before hiring begins.
Map the required investment-professional headcount against actual hiring need , do not over-hire relative to the AUM tier, as spending thresholds scale with headcount.
Draft role profiles and salaries that will independently clear the Employment Pass qualifying salary and the COMPASS framework, not just the MAS “investment professional” definition.
File the 13O or 13U application with MAS in parallel with, or slightly ahead of, the first Employment Pass applications for investment professionals.
If GIP Option C is in scope, align the family office’s AUM and deployment plan with EDB before submitting the GIP application, since EDB assesses the investment plan and ICA assesses the residency application.
Once MAS approval and the first work passes are in hand, calendar the annual declaration deadlines and build an evidence trail (payroll records, time-use logs for investment professionals) from day one.
Review the headcount and AUM position at least once a year ahead of the MAS declaration, and again before any GIP conversion milestone, so that shortfalls are caught early rather than at the point of renewal or conversion.

Common mistakes and gotchas

Counting a family member as the sole non-family investment professional , MAS requires a genuine non-family hire, and this is checked.
Hiring investment professionals at salaries that satisfy the MAS definition but fall short of the Employment Pass qualifying salary or COMPASS pass mark, leaving the hire in immigration limbo.
Treating GIP Option C as independent of the 13O/13U tax position , EDB and MAS coordinate, and an unresolved tax-scheme headcount shortfall will stall the PR conversion.
Under-budgeting the local business spending requirement, which rises with AUM and is reviewed annually , family offices that set up at the AUM floor sometimes find the spending bar has moved by the time of their first annual review.
Delaying the annual MAS declaration, which can put the tax-exempt status itself at risk regardless of how the hiring was structured.
Assuming a Personalised Employment Pass automatically satisfies the “investment professional” headcount test , MAS assesses time spent on qualifying activity, not just pass type.

FAQs

What is the minimum AUM for a Section 13O family office?
S$10 million at the point of application, with a commitment to reach S$20 million within two years, under MAS’s published conditions for the scheme.

Do family office investment professionals need an Employment Pass?
In most cases yes , non-citizen, non-PR investment professionals are typically hired on the Employment Pass, which is assessed separately from (though alongside) the MAS staffing conditions.

Can family office hiring alone satisfy GIP Option C?
Only if the AUM, deployment and headcount thresholds specific to Option C , higher than the base 13O/13U conditions , are met, including at least one Singapore citizen investment professional.

What is the main staffing difference between 13O and 13U?
13O requires at least two investment professionals; 13U requires at least three, reflecting the higher AUM and typically greater operational complexity of 13U funds.

How long does the combined family office and hiring process take?
Allow roughly two to three months for MAS approval of the tax scheme running in parallel with Employment Pass applications, and four to six months if a GIP Option C application is also in progress.

Related guides

For the fund-structuring and MAS approval mechanics behind 13O and 13U, see Raffles Corporate Services’ Family Office Principal track under ONE Pass and GIP , Eligibility and requirements checklist. For the broader residency picture, Singapore Secretary Services’ How to Move to Singapore as a High Net Worth Individual: All Pathways 2026 sets out how GIP compares with other high-net-worth pathways. If GIP itself , rather than the family office hiring angle , is your main question, see our own Global Investor Programme (GIP) , Options A, B and C , Eligibility and requirements checklist.

Section 13O of the Income Tax Act 1947 provides the statutory basis for the onshore fund tax exemption scheme that most single family offices apply under, while Section 13U of the Income Tax Act 1947 provides the equivalent exemption for the enhanced-tier scheme used by larger funds. Separately, Section 5(1) of the Employment of Foreign Manpower Act 1990 provides that no person shall employ a foreign employee unless that employee holds a valid work pass issued under the Act , the statutory backbone under which every non-citizen investment professional hire must be assessed, regardless of how the MAS tax-scheme conditions are satisfied.

For the current MAS-administered conditions, consult the Economic Development Board at www.edb.gov.sg (which administers the Global Investor Programme) and the Immigration and Checkpoints Authority at www.ica.gov.sg (which assesses and grants the resulting permanent residence applications).

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.