The Singapore manager with a Swiss L-QIF

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The reverse case has become possible since 1 March 2024, when the limited qualified investor fund (L-QIF) was introduced into the Collective Investment Schemes Act (CISA; KAG). An L-QIF is a Swiss fund for qualified investors that needs no FINMA approval or supervision of the fund itself, provided it is administered by a FINMA-licensed fund management company or managed by a FINMA-licensed manager of collective assets (see Part E, Chapter VI). A Singapore manager cannot be the L-QIF's responsible manager, because that role is reserved to Swiss-licensed institutions. It can be appointed as a sub-manager by delegation under Art. 14 CISA and the FinIA rules on delegation, provided it is subject to recognised supervision, which MAS supervision satisfies.¹

The tax position of the Singapore sub-manager is governed by the DTA (Chapter IX of this Part). Sub-advisory fees paid from Switzerland to Singapore are business profits taxable only in Singapore unless the Singapore manager has a Swiss permanent establishment. The manager's staff who travel to Zürich should therefore not conclude contracts there. The L-QIF itself is transparent for Swiss tax purposes if it is a contractual fund or SICAV. Its Singapore investors are taxed in Singapore on distributions according to their own status. For an individual investor that means no tax on capital distributions and no tax on income that is foreign-sourced and received by a resident individual. The L-QIF route is attractive for Singapore managers who want a European vehicle without the cost of a Luxembourg RAIF and who have Swiss or Liechtenstein investors to serve.

Notes

Collective Investment Schemes Act (CISA; KAG), SR 951.31, Arts 118a ff. (L-QIF, in force 1 March 2024) and Art. 14 (delegation); Financial Institutions Act (FinIA; FINIG), SR 954.1, Arts 27 and 35 (delegation of tasks). ↩

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

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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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