Raffles Consulting Services
Separate qualifying investment roles from operations, finance and administration when hiring for a Singapore single family office.
For the Singapore family-office tax incentive schemes, an investment professional is expected to work mainly as a portfolio manager, research analyst or trader. Finance, accounting, cash monitoring, legal administration, tax support and trade settlement are important jobs, but MAS says they are not qualifying investment professional roles by themselves.
This distinction should shape hiring plans and job descriptions before an application is made. A senior title does not decide the answer. The person’s actual responsibilities, time allocation, experience and evidence of investment decision work matter.
MAS identifies three core role types
The current MAS answer on qualifying investment professionals names portfolio managers, research analysts and traders. It gives examples such as developing investment strategies, building and managing portfolios, researching assets, making buy or sell recommendations, trading financial instruments, managing liquidity and structuring deals.
The common thread is substantive investment management. The employee analyses or decides how capital is invested, monitors the result and acts within an approved mandate. A role that only processes another person’s decision does not become an investment role because it sits inside an investment entity.
Separate investment work from support work
| Activity | Likely classification | Evidence to retain |
|---|---|---|
| Sets asset allocation and manages portfolios | Investment professional work | Mandate, committee papers and portfolio decisions |
| Researches securities and recommends trades | Investment professional work | Research notes, models and recommendation records |
| Executes and structures investment trades with discretion | Investment professional work | Authority matrix, orders and trade rationale |
| Runs budgets, accounts and capital calls | Operations or finance | Finance role description and process records |
| Handles contracts, wires and settlements | Administration or operations | Maker-checker records and service procedures |
| Supports tax planning or compliance | Tax or professional support | Advice, filings and engagement records |
Avoid mixed roles that exist only on paper
Small family offices often need employees to cover several functions. A portfolio manager may also review cash or help with board papers. The issue is whether investment management remains the primary job. Write the expected time split and decision authority into the role description, then compare it with actual work each quarter.
A chief financial officer who occasionally attends an investment committee is not automatically an investment professional. Nor is an operations employee who enters trades chosen by someone else. If a genuine hybrid role is planned, document the investment responsibilities, competence and reporting line, and seek advice on the current scheme requirements.
Build a file for each qualifying employee
Keep the employment agreement, job description, curriculum vitae, qualifications, work history and Singapore work location. Add practical evidence: investment committee papers, research notes, signed recommendations, portfolio reports, trade approvals and a record of delegated limits. The file should show what the person actually did during the relevant period.
Do not include unnecessary personal data in general working folders. Restrict access to employment and investment records, keep retention rules, and separate confidential family information from documents supplied to outside providers.
Review the role after hiring
A compliant job description can drift away from the work actually performed. Review each proposed qualifying role at least quarterly. Compare the person’s calendar, committee attendance, research output, trade decisions and portfolio responsibilities with the agreed role. Record extended leave, secondments, departures and material changes in duties when they could affect a scheme condition.
Payroll and human-resources records should agree with the investment evidence. If an employee is described as a full-time portfolio manager but spends most of the year on family administration or finance, the office should not ignore the difference. Correct the operating model, hire the missing capability or obtain advice on the effect. Annual declarations should be supported by the year’s records, not recreated from titles at filing time.
Plan the rest of the team honestly
The EDB’s single family office setup guide tells families to build a board and executive committee, hire management and investment professionals, and appoint a Singapore-based fund administrator. That does not mean every function must be internal. Legal, tax, audit, administration, custody, technology and specialist investment work may be outsourced where suitable.
Make a role list based on the family’s needs. Mark each function as employed, outsourced or retained by the family. Then identify which employees are proposed as qualifying investment professionals and which are operational support. This gives the board a realistic cost plan and prevents one person from being counted in several incompatible ways.
Keep regulatory status separate from tax incentive staffing
MAS states that a single family office relying on the current fund-management licensing exemption must file a Notice of Commencement of Business, maintain the required bank accounts and submit annual returns. The MAS licensing exemption answer should be read with the family office’s facts.
A licensing exemption and a tax incentive are different questions. The office may satisfy the family-ownership conditions for an exemption but still need to meet the separate terms of a Section 13O or 13U approval. Likewise, hiring a person with an investment title does not by itself satisfy every incentive condition.
Example: four people, two different functions
Assume a family office hires a chief investment officer, an equity analyst, a finance manager and an operations associate. The chief investment officer sets portfolio strategy and approves investments. The analyst researches companies and makes documented recommendations. Those two roles align with the MAS examples.
The finance manager prepares budgets and capital accounts, while the operations associate handles settlement and fund wires under dual approval. Those functions are necessary, but they do not match the qualifying investment professional examples. The office records them as support roles and does not rely on their titles to meet an investment staffing condition.
Families can connect this hiring review with the investment policy and the family office decision structure. Our Family Office and UHNW Advisory hub explains how governance, staffing, tax and service providers fit together.