MAS (Monetary Authority of Singapore)

The Variable Capital Company is a corporate fund structure introduced by Singapore in January 2020 under the Variable Capital Companies Act. A VCC can be set up as a single standalone fund or as an umbrella structure with multiple sub-funds, each with segregated assets and liabilities. It offers operational flexibility such as issuing and redeeming shares without shareholder approval, making it well-suited for both open-ended and closed-ended PE/VC fund strategies.

An LFMC holds a Capital Markets Services (CMS) licence from MAS to conduct fund management activities in Singapore. LFMCs are subject to comprehensive regulatory requirements including minimum base capital of S$250,000 (or S$1 million for retail-facing managers), ongoing compliance, risk management, and audit obligations. This licence is required for managers serving retail investors or managing assets above the thresholds applicable to RFMCs.

An RFMC is a fund management company registered (rather than licensed) with MAS, permitted to manage assets for up to 30 qualified investors with total AUM not exceeding S$250 million. RFMCs benefit from a lighter regulatory framework compared to LFMCs, making this an accessible entry point for emerging GP teams setting up in Singapore while still being subject to MAS oversight and anti-money-laundering requirements.

The Section 13R scheme (previously known as 13CA, renumbered in the 2022 Income Tax Act revision) provides tax exemption on specified income derived from designated investments by an approved fund managed by a Singapore-based fund manager. It applies to funds structured as companies and requires MAS approval, a minimum fund size of S$20 million at the point of application, a local investment spending commitment, and annual reporting to MAS.