Jurisdictions · Compare
Singapore vs Dubai (DIFC) for a Family Office (2026)
Our view
Singapore sets no licence and no minimum wealth for the office itself. The office must be a Singapore company with a locally resident director, notify MAS, bank with a MAS-licensed bank and file a yearly return. Its main draw, income tax exemption for the family's fund, comes with real substance: at least SGD 20 million in the fund, two or three investment professionals, SGD 200,000 or more of local spending a year and part of the fund in qualifying investments. DIFC sets a higher bar to start, USD 50 million and a licence, but the UAE has no personal income tax, against a top rate of 24% in Singapore. Families who want an Asian base and permanent residence (from SGD 200 million under management) will look at Singapore. Families who want a Gulf base and a 10-year Golden Visa from AED 2 million will look at DIFC.
Key differences
- Licence: none in Singapore (a notice to MAS), against a licence from the DIFC Registrar.
- Minimum wealth: none for Singapore's licensing exemption (SGD 20 million for the 13O tax incentive), against USD 50 million in DIFC.
- Personal income tax: up to 24% in Singapore, none in the UAE.
- Corporate tax: 17% in Singapore, with partial exemption on the first SGD 200,000 and possible exemption for the family's fund, against 9% above AED 375,000 in the UAE, with 0% on qualifying income for Qualifying Free Zone Persons (the FTA says an unregulated family office's wealth and fund management income does not qualify).
- Residence: permanent residence in Singapore through the Global Investor Programme (SGD 200 million under management, SGD 50 million invested in Singapore, EDB approval), against a 10-year Golden Visa from AED 2 million in the UAE.
- Inheritance: no estate duty in Singapore since 15 February 2008; none in the official UAE list of taxes.
Side by side
| Topic | Dubai (DIFC) | Singapore |
|---|---|---|
| Licence | Family Office licence from the DIFC Registrar; no DFSA licence | No licence: class exemption, notify MAS within 14 days |
| Minimum wealth | USD 50 million in family net assets, confirmed every year | None for the exemption; SGD 20 million (13O) or SGD 50 million (13U) for tax incentives |
| Who counts as family | A living ancestor and their descendants, or descendants of an ancestor up to three generations back, with spouses, stepchildren and adopted children | Descendants of a common ancestor up to five generations back, with current and former spouses, in-laws, adopted children and stepchildren |
| Serving several families | Registrar's approval to serve several families (USD 50 million each); a DFSA licence to give them financial services | MAS capital markets services licence for fund management |
| Law and courts | DIFC laws; English-language DIFC Courts | Singapore law and courts |
| Substance | No minimum staff or spending rule found; 0% tax status needs adequate substance | Locally resident director; for tax incentives, 2 or 3 investment professionals (one non-family), SGD 200,000 to SGD 1 million local spending a year and qualifying investments |
| Holding vehicles | Company, foundation, trust, prescribed company (SPV) | Company, limited partnership, LLP, variable capital company (VCC), trust; no foundation law found |
| Corporate tax | UAE corporate tax: 0% up to AED 375,000, 9% above | 17%, with partial exemption on the first SGD 200,000 |
| Family office tax | 0% only on qualifying income, not unregulated wealth management; foundations can be transparent | Funds can apply for income tax exemption under 13O, 13OA or 13U (schemes run to 31 December 2029) |
| Personal income tax | None | Progressive, top rate 24% |
| Inheritance tax | None in the official UAE list of taxes | No estate duty for deaths on or after 15 February 2008 |
| Wills and succession | Non-Muslim wills registered with the DIFC Courts Wills Service | Wills and the Intestate Succession Act; Muslim estates follow Faraid |
| Residence | 10-year Golden Visa from AED 2 million in property or investments | Permanent residence via the Global Investor Programme: SGD 200 million under management, SGD 50 million invested in Singapore |
| Time to set up | No official figure found | Company: most registered soon after payment, up to 15 working days if complex, 14 to 60 days if referred; no official time for 13O/13U |
| Official fees | USD 12,000 Family Office Licence under the 2023 rules (may be yearly), plus company fees | SGD 315 to register a company; no official fee found for the MAS notice or 13O/13U applications |
