Singapore taxes individuals at moderate rates and does not tax gains of a capital nature. The articles collected here explain the family office model, the tax incentive conditions, the Global Investor Programme, tax residence, the arithmetic of living in Singapore or Switzerland, timing a token event around a move, anti-avoidance and the reporting of holdings under the CRS and CARF.
Resident individuals pay progressive rates up to 24 per cent above S$1 million. Non-resident employees pay the higher of a flat 15 per cent or the resident rates. Singapore does not tax gains of a capital nature, while trading gains remain taxable. Estate duty was removed for deaths on and after 15 February 2008.
An individual is resident if physically present or employed in Singapore for at least 183 days in the year, subject to the administrative concessions described in the book.
A family that moves still has to consider the tax rules of the home country, including exit taxes and treaty residence. Singapore implemented the Common Reporting Standard with first exchanges in September 2018, so assets held here are reported abroad.
If you hold digital assets, ask whether you are a trader or an investor, and plan the timing of a token event around any move.
Start with tax residence of individuals, the arithmetic side by side or the Singapore family office model.
The Singapore family office model
A single family office in Singapore is a company that manages the assets of one family and nothing else. The structure that MAS and IRAS have in mind has two layers. Read more Singapore · TaxThe licensing exemption and the 2023 class exemption proposal
A family office that manages only the assets of a single family does not need a capital markets services licence. Read more Singapore · TaxThe tax incentive conditions for single family offices
Single family office funds obtain their exemption under section 13O or 13U, but the conditions are stricter than for commercial funds and have been tightened twice. Read more Singapore · TaxCrypto in the family office's asset mix
The designated investments problem of Chapter IV strikes a crypto family office harder than a commercial fund, because the family's wealth often consists largely of the tokens that made it. Read more Singapore · TaxThe August 2023 case and the tightening of practice
In August 2023 the Singapore Police Force arrested ten foreign nationals and seized or froze assets eventually valued at more than S$ 3 billion in what became the largest money-laundering case in… Read more Singapore · TaxThe Global Investor Programme
The Global Investor Programme, administered by the Economic Development Board, grants permanent residence to investors who commit capital to Singapore. Read more Singapore · TaxThe comparison with Zug lump-sum taxation
The Singapore family office is often weighed against the Swiss lump-sum regime described in Part G, Chapter VI, although the two instruments are built on different logics. Read more Singapore · TaxTokens as remuneration
Most digital-asset businesses pay part of their people in tokens. Read more Singapore · TaxSection 10(6) and the share plan rules applied to tokens
Singapore has a specific regime for employee share plans. Section 10(6) taxes gains from rights to acquire shares, meaning options and share awards, at the time of exercise or vesting. Read more Singapore · TaxThe deemed exercise rule and the QEEBR deferral
Two features of the share plan regime are relevant to a mobile crypto workforce. Read more Singapore · TaxTax residence of individuals
An individual is resident in Singapore for a year of assessment if he resides in Singapore in the preceding calendar year, except for temporary absences, or if he is physically present or exercises… Read more Singapore · TaxThe pass system
Nobody lives and works in Singapore without a pass. The pass system is in practice a filter that decides which founders and employees Singapore wants. Read more Singapore · TaxRelocating from Switzerland to Singapore
A founder who moves from Zug to Singapore faces a sequence of questions on each side. Read more Singapore · TaxRelocating from Singapore to Switzerland
The reverse move is less common but increasingly seen as families return to Europe. Singapore has no exit tax other than the deemed exercise rule, so the founder leaves with his tokens untaxed. Read more Singapore · StructuringFour ways to hold
A private client with a material digital-asset position has four ways to hold it: personally, through a company, through a foundation or through a trust. Each hub favours a different combination. Read more Singapore · StructuringHolding personally
Personal holding is the default and, for a tax resident of either hub, often the best. Read more Singapore · StructuringHolding through a company
A Swiss holding company for personal digital assets is rarely tax-efficient. The company pays profit tax on realised gains at just under 12 per cent in Zug. Read more Singapore · StructuringHolding through a foundation
Swiss law permits family foundations only for the limited purposes of Art. 335 CC: the costs of upbringing, endowment, support or similar purposes of family members. Read more Singapore · StructuringHolding through a trust
Singapore is a mature trust jurisdiction. The Trustees Act 1967 provides the default powers and the Trust Companies Act 2005 licenses professional trustees. Read more Singapore · StructuringBanks and custodians that take crypto
A private client needs three relationships: a bank for fiat, a custodian for tokens and, often, a bank that will do both. Switzerland is further ahead. Read more Singapore · StructuringInsurance
Insurance for digital assets exists in two forms. The custodian's own crime and specie cover protects the custodian's balance sheet and indirectly the client. Read more Singapore · StructuringThe Singapore family office with Swiss members
The Singapore family-office wave of 2019 to 2023 brought several hundred single-family offices to Singapore under the s. 13O and s. 13U incentives, many of them with substantial digital-asset… Read more Singapore · StructuringReporting: CRS, CARF and the digital-asset wealth statement
Every structure in this chapter is reported. Under the Common Reporting Standard, banks and custodians in both hubs report accounts of non-resident clients to their home tax administrations. Read more