Raffles Consulting Services
Singapore VCC and fund structures: what to decide before choosing a vehicle
An overview of VCCs, fund-management boundaries, 13O and 13U considerations, and the closure of the original VCC Grant Scheme.
A VCC is a vehicle, not the whole answer
The Variable Capital Company was designed for investment funds. It can be a standalone fund or an umbrella with sub-funds whose assets and liabilities are segregated. Its capital can vary with subscriptions and redemptions, and it can accommodate open-ended and closed-ended strategies.
Questions to answer first
- What strategy and assets will the fund hold?
- Who are the investors and what protections and reporting do they expect?
- Who will manage the assets, and does that activity require a MAS licence or exemption?
- Which administrator, custodian, auditor, legal counsel and other providers are needed?
- Can the conditions for a Singapore fund tax incentive be met over time?
13O and 13U
Sections 13O and 13U can exempt specified income of qualifying funds, subject to conditions that may include Singapore management, spending, assets under management, investment-professional and investment requirements. The conditions and application process should be reviewed for the specific structure rather than summarised as a guaranteed “tax-free” result.
The VCC grant is closed
The original VCC Grant Scheme closed on 15 January 2025. A current website should not present it as an available subsidy unless MAS or another authority launches a replacement.