The Global Investor Programme (GIP) completed a structural overhaul of its family office route (Option C) in 2025. The key change: the minimum fund size under the 13O tax incentive has risen to S$50 million, and a mandatory S$10 million local investment deployment is now required — this sum must be committed to Singapore-listed equity or qualifying debt securities within 12 months of fund approval. The 2024 jump from S$20 million to S$50 million already eliminated a number of smaller single-family offices, and the 2025 local investment threshold closed the “fund registered but idle” loophole. If you plan to submit a GIP application through a family office in 2026, your fund structure, hiring timeline and investment deployment plan must be aligned before the application window opens. The transition protection period for legacy structures has closed.
13O structure: thresholds, deployment and local spending
Minimum fund size and submission threshold
When submitting a GIP application, your family office must commit to at least S$50 million in assets under management (AUM). The Monetary Authority of Singapore (MAS) requires the fund administrator to issue a signed confirmation letter proving that capital commitments are in place. Applications below this amount are returned outright at the GIP pre-screening stage. Note: this S$50 million is the minimum fund-level size, not your personal investable assets. GIP Option C imposes a separate requirement for personal investable assets — no less than S$200 million (raised from S$100 million in 2024), computed on a combined household basis and including assets held by a spouse and children under 21, but excluding the main residence and trust assets not directly controllable.
S$10 million local investment: mandatory 12-month deployment
The Monetary Authority of Singapore’s Section 13O and 13U Tax Incentive Guidelines (2024 edition) set out the list of qualifying investment instruments. Acceptable instruments include:
- Equity listed on the Mainboard or Catalist board of the Singapore Exchange
- Qualifying debt securities as defined under section 13(16) of the Income Tax Act
- Units in MAS-authorised collective investment schemes
- Investments made through a Singapore-licensed fund manager
Real estate and private company equity do not count towards this S$10 million. This is a common misconception: many applicants treat commercial property or shares in related companies held by the family office as local investment, and MAS excludes them directly during audit.
Annual local business expenditure: from S$200,000
Following the 2024 amendment, annual local business expenditure under the 13O structure rose from S$100,000 to S$200,000. Expenditure must occur in Singapore and be paid to Singapore-resident entities. Qualifying categories include:
- Salaries of local staff (Singapore citizens or permanent residents)
- Office rental
- Legal, accounting and fund administration fees paid to Singapore-licensed service providers
- Fund audit fees
Salaries of foreign employees or Employment Pass (EP) holders do not count. The 2025 update clarified that at least one local employee must be a full-time employee; part-time or outsourced contract staff do not satisfy the condition. MAS checks CPF contribution records and employment contracts.
GIP Option C application process and document preparation
Eligibility criteria and timeline planning
The processing period for GIP Option C is typically 8–12 months, longer than the 6-month standard period for Options A and B. Submission is recommended at least 6 months before the planned relocation date. Contact Singapore is the designated receiving agency for GIP, and all materials are submitted through its system.
All of the following conditions must be met:
- Personal investable assets of at least S$200 million (computed on a combined household basis)
- At least 5 years of entrepreneurial or investment management experience
- Family office managing assets of at least S$50 million at the time of application
- Family office must be a Singapore-registered company with a local registered address
Core document checklist
Submit the originals or certified copies of the following documents:
- GIP application form (Form A) — downloaded from the Contact Singapore website
- Certified copies of passport and identity documents
- Bank statements and portfolio reports for the past 24 months
- Audited financial statements of the family office (if incorporated)
- Detailed deployment plan for the S$10 million local investment
- Local staff recruitment plan
- Family office business plan covering the 5-year Re-Entry Permit (REP) period
All documents must be in English. Chinese-language documents require a certified translation by a Singapore-registered translator. Contact Singapore officers verify translation accuracy during the interview stage.
Ongoing compliance obligations after approval
Annual filing and random audits
After obtaining GIP approval and the 13O tax incentive, the following must be submitted to MAS each year:
- Audited fund financial statements (within 6 months after the financial year end)
- 13O conditions compliance declaration (Form 13O-1)
- Full list of all investments held by the fund, including the local investment portion
- Payroll report showing local employee salaries and CPF contribution records
MAS conducts random audits of 13O funds. Selected funds must provide supporting documents within 14 days. Failure to respond in time results in suspension of the tax incentive.
Local employees: employment duration and replacement window
The 2025 policy update introduced a new requirement: local employees must be employed for at least 9 months in each calendar year. If an employee resigns or is dismissed, you have 60 days to find a replacement. The fund retains its tax incentive during this period, but the year’s business expenditure requirement is reduced proportionally. MAS does not set a minimum salary; if the employee needs an EP, they must meet the Ministry of Manpower’s (MOM) current EP qualifying salary threshold (from S$5,600 per month for general industries, higher for financial services). Do not hire relatives or nominal staff — MAS checks employee backgrounds, and will launch an investigation if the person lacks investment management or fund administration experience.
Local investment deployment: 3-month grace period
The S$10 million local investment must be deployed within 12 months from the date the tax incentive is approved. MAS allows a 3-month grace period, provided you can show the delay was caused by uncontrollable factors such as market conditions or regulatory approval. A written request with supporting evidence is required. Missing the deployment deadline revokes the first year’s tax incentive. If the revocation occurs within the first two years of the 5-year REP, the GIP REP is cancelled. You may reapply for the tax incentive in the following year, but GIP status cannot be reinstated.
Costing: actual total expenditure for a S$50 million fund
One-time costs
- Fund setup fees (legal, administrative, audit): S$50,000 – S$150,000
- GIP application fee: S$1,000 (non-refundable)
- Translation and certification fees: depending on document volume, about S$2,000 – S$5,000
Annual recurring costs
- Local employee salaries (based on EP salary thresholds: from S$5,600 per month for general industries, from S$6,200 per month for financial services): calculated by actual headcount
- Office rental (estimated at 200 square feet in the Central Business District): S$60,000 – S$120,000 per year
- Professional service fees (audit, tax, legal): S$50,000 – S$100,000 per year
- Local investment management fee (estimated at 0.5% rate): S$50,000 per year
Total annual expenditure is about S$220,000 – S$330,000, covering the S$200,000 minimum business expenditure requirement. Note: the funding cost (opportunity cost or financing cost) of the S$10 million local investment is not included. If the funds come from external financing, actual expenditure will rise materially.
Cross-border tax considerations
For applicants with a China background, the source of funds for a S$50 million fund may involve cross-border transfer of onshore assets. China’s foreign exchange administration still imposes an annual foreign exchange purchase limit of S$50,000 for individual outbound investment. In practice, applicants usually route through offshore existing assets, Hong Kong accounts, or compliant ODI (Outbound Direct Investment) channels. The Inland Revenue Authority of Singapore (IRAS) exempts 13O fund gains from tax, but Chinese tax authorities may assert taxing rights over fund gains under the China-Singapore tax treaty. Cross-border tax structuring should be completed before fund setup, not adjusted afterwards.
Dependant relocation and children’s education transition
Dependant’s Pass (DP) and Long-Term Visit Pass (LTVP+)
After GIP approval, the main applicant’s spouse and children under 21 may apply for a Dependant’s Pass (DP). The main applicant’s parents may apply for a Long-Term Visit Pass (LTVP+), but must meet a salary requirement of at least S$12,000 per month; among children over 21, only unmarried persons with disabilities qualify for the LTVP+. If a relocating spouse wishes to work in Singapore, a separate application is required under the Ministry of Manpower’s (MOM) Work Permit requirements; the current provisions in the materials on dependants’ work rights state that eligible Long-Term Visit Pass holders may be able to work in Singapore. This is favourable for the relocating spouse’s career planning.
Children’s education transition
Singapore public schools admit by school zone, and children of GIP holders may apply on a priority basis. But waiting lists at international schools (such as UWCSEA and SAS) are typically 6–12 months. It is advisable to start the school application process during the GIP application stage. For families with a China background, note: Singapore primary and secondary mathematics and science curricula are more demanding than their Chinese counterparts at the same level, but English-language requirements are higher. Some families arrange a 6–12 month bridging course before enrolment.
Closing: 5 actionable takeaways
- Before submitting a GIP Option C application in 2026, confirm the family office fund size is at least S$50 million and that the S$10 million local investment deployment plan is included in the business plan.
- Local employee recruitment must begin before fund approval, ensuring at least 9 months of employment in the first calendar year; do not use nominal staff.
- The S$200,000 annual business expenditure must be paid entirely to Singapore-resident entities; foreign employee salaries do not count.
- Cross-border fund transfers must be arranged 6–12 months in advance to avoid delaying fund setup due to foreign exchange controls.
- Children’s school applications should proceed in parallel with the GIP application; international school waiting lists may affect the relocation timeline.