As of January 1, 2025, Singapore has implemented significant updates to its fund tax incentive schemes—Sections 13O, 13U, and the newly introduced 13OA—affecting both Single Family Offices (SFOs) and non-SFO funds.

• Minimum Assets Under Management (AUM): Funds must maintain a minimum AUM of SGD 5 million in Designated Investments (DI) by the end of each financial year. Previously, there was no minimum AUM requirement.
• Investment Professionals (IPs): The fund’s Singapore-based manager must employ at least two investment professionals throughout the fund’s basis period.
• Local Business Spending (LBS): A new tiered LBS requirement has been introduced:
  • AUM < SGD 250 million: SGD 200,000
  • SGD 250 million ≤ AUM < SGD 2 billion: SGD 300,000
  • AUM ≥ SGD 2 billion: SGD 500,000
• Removal of New Company Condition: Funds applying under Section 13O no longer need to be newly set up, allowing existing funds to qualify for incentives.

• Minimum AUM: Funds must maintain a minimum AUM of SGD 50 million in DI at the end of each financial year.
• Investment Professionals: The fund manager must employ at least three investment professionals.
• Local Business Spending (LBS): Similar to Section 13O, a tiered LBS requirement applies based on the fund’s AUM
  • AUM < SGD 250 million: SGD 200,000
  • SGD 250 million ≤ AUM < SGD 2 billion: SGD 300,000
  • AUM ≥ SGD 2 billion: SGD 500,000
• Structural Simplifications: For funds structured with special purpose vehicles (SPVs) or trading feeders, AUM and LBS requirements will now be applied at the single-fund entity level, reducing administrative complexity.

• Introduction of Section 13OA: This new scheme extends tax incentives to Singapore Limited Partnerships (LPs), particularly benefiting small private equity and venture capital funds.
• Economic Criteria: The incentive conditions mirror those of the existing Section 13O framework, including minimum AUM and LBS requirements.

From 3 to 6 February 2025, the UN intergovernmental negotiating committee (Committee) held an organisational session to draft a UN Framework Convention on International Tax Cooperation (Convention). Key decisions included the composition of the committee’s bureau, choosing “prevention and resolution of tax disputes” as the topic for the convention’s second early protocol, and adopting a simple majority decision-making process for the convention negotiations with a two-thirds majority required for protocols.

The UN is moving to take a larger role in international tax development. There will be opportunities for stakeholders to contribute to the committee’s work, and companies should monitor developments and engage when possible. The UN is seeking to conclude negotiations by 2027.

Where multinationals shift profits to low- or no-tax locations where they have little or no economic activity or erode tax bases through deductible payments like interest or royalties, it costs countries USD 100-240 billion in lost revenue annually. A two-pillar solution reveals the latest tax developments evolving around a two-pillar solution and the key building blocks that are foundational to building up your readiness.

On 1 February 2025, the Indian finance minister presented the Union Budget for 2025–26. The budget focuses on various development measures that include boosting manufacturing and ‘Make in India,’ enabling employment-led development, investing in people, the economy, and innovation, securing energy supplies, promoting exports, and nurturing innovation.

On 16 December 2024, the Legislative Assembly of the Macau Special Administrative Region (Macau SAR) passed the bill for approval of the Tax Code (new legislation). This new legislation not only clarifies and strengthens the tax legal system in the Macau SAR but also establishes a modern tax system in line with international standards. The Chief Executive of the Macau SAR signed and ordered the publication of the new legislation on 28 December 2024, which was then officially published in the Macau SAR Gazette on 30 December 2024. To allow sufficient time for relevant sectors to adopt, the majority of the provisions of the new legislation will take effect on 1 January 2026. However, the definition of tax resident and certain amendments to the stamp duty regulations have come into effect as of 1 January 2025 and 31 December 2024, respectively.

The Income Tax (Exemption) Order 2025 (2025 Order) was gazetted on 13 February 2025 and provides exemption from income tax on various payments from specified Labuan persons.

On 3 January 2025, Vietnam signed the multilateral competent authority agreement on the exchange of country-by-country reports (MCAA CbCR).

This states what this means for companies and groups in Vietnam which fall within the CbCR rules.

Among the developments in early 2025 are:

• Canada –Release of draft legislation to increase the capital gains inclusion rate
• Cyprus – Extension of application of debt restructuring provisions
• France – Finance Law for 2025 finally adopted
• United Arab Emirates – UAE implements Pillar Two effective 1 January 2025
• United States – Trump Administration announces steep tariffs on Canada, Mexico and China
• India – Guidelines issued for application of PPT under India tax treaties

Form for fund management companies, including venture capital fund managers, to notify MAS of changes to their particulars and particulars of their directors, relevant professionals or shareholders. This form must be submitted within 14 days after the date of the change. You may refer to the following PDF specimen form to prepare your submission. This specimen form should not be submitted to MAS. All official submissions must be made online via MAS-Tx.