Fund manager licensing and taxation

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A fund manager in Singapore must hold a capital markets services licence for fund management under the Securities and Futures Act 2001 or qualify for an exemption. Since 1 August 2024 the only licence categories are the licensed fund management company for accredited and institutional investors (A/I LFMC), the retail LFMC and the venture capital fund manager regime, after MAS abolished the registered fund management company category and transitioned its members.¹ A manager whose fund invests in payment tokens is managing "capital markets products" only to the extent the tokens are securities or derivatives. For pure payment tokens the manager is outside the fund management licence. It may instead be a DPT service provider under the Payment Services Act if it deals in or arranges the tokens for customers, which is the licensing crossroads described in Part K, Chapters I and II. Most Singapore crypto managers hold a CMS licence for fund management and structure their mandates so that token dealing is done by the fund and not by the manager.

The manager's own taxation follows the Financial Sector Incentive for fund management (FSI-FM), which taxes qualifying fee income at a concessionary rate of 10 per cent for an award period, subject to conditions on headcount and business spending. Budget 2024 introduced an additional tier of 13.5 per cent for certain FSI awards and extended the scheme.² A Swiss-owned manager that sets up in Singapore applies for FSI-FM through MAS once it has a licence and a business plan. The incentive is one of the reasons why the manager is often the first Singapore entity in a Swiss group's expansion.

Notes

Securities and Futures Act 2001, s. 82 and Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations; MAS, Guidelines on Licensing, Registration and Conduct of Business for Fund Management Companies (SFA 04-G05), as revised 2024. ↩
Income Tax Act 1947, s. 43J and the Income Tax (Concessionary Rate of Tax for Financial Sector Incentive Companies) Regulations; MAS, FSI scheme guidelines as revised following Budget 2024. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

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