Funds, VCCs and Cross-Border Structures

Choose the vehicle for the mandate

Singapore’s Variable Capital Company can operate as a standalone fund or an umbrella with segregated sub-funds. It may support open-ended or closed-ended strategies, but it is only one part of the structure. The manager, offering, service providers, investor terms, tax position and operating substance must be planned together.

Questions to resolve early

• Who are the investors, where are they located and what reporting do they require?
• What assets and markets will the strategy cover?
• Will the arrangement fall within a regulated fund-management or offering perimeter?
• Should the vehicle be a VCC, company, limited partnership, unit trust or another jurisdictional structure?
• Can Singapore fund tax incentive conditions under sections 13D, 13O/13OA or 13U be met and maintained?
• What administration, custody, audit, valuation, AML/CFT and governance arrangements are needed?

Cross-border and offshore structures

Offshore vehicles are not a product to be selected in isolation. We assess the commercial purpose, beneficial ownership, tax residence, substance, treaty access, transfer pricing, anti-avoidance, reporting and Singapore’s foreign-sourced income and disposal-gain rules. Where fund documents, offering terms, regulatory advice or formal legal opinions are required, we coordinate with Singapore law firms whose lawyers have the relevant funds, corporate or cross-border speciality.

From structure design to incorporation

Raffles Consulting Services advises on vehicle selection, commercial purpose, governance, tax coordination and the regulatory perimeter. Our affiliated company, Raffles Corporate Services Pte Ltd, carries out Singapore company and VCC incorporations, corporate filings and related licence applications. Offshore implementation is coordinated with suitable providers in the relevant jurisdiction.