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Can S13O/OA/U SFO funds hold investments in operating businesses of the beneficial owner or his family?


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Are the operating businesses of the beneficial owner or his family allowed to be part of the S13O/OA/U fund structure?

What is considered as relevant experiences or academic qualifications of qualifying IPs for the purposes of the S13O/OA/U schemes for SFO funds?

Regarding Option 2 of the CDR, will an investment into a limited partnership (“LP”) fund qualify?

What are the expected job roles of qualifying IPs for the purposes of the S13O/OA/U schemes for SFO funds?

Regarding Option 2 of the CDR, will an investment into a fund distributed by a global fund management company count if the global fund management company has a related licensed financial institution entity in Singapore?

Regarding Option 3 of the CDR,  a) What are the definitions of: (i) operating companies and (ii) substantive presence in Singapore?  b) Does it count if the S13O/OA/U SFO fund invests into a foreign holding company that holds a non-listed Singapore-incorporated company with operating business(es) and with substantive presence in Singapore?  c) Would an investment into a Singapore holding / joint venture company which owns a wholly-owned Singapore subsidiary count?

Under the 5Jul23 conditions, what happens if an S13O/OA/U SFO fund’s AUM in DI falls below the minimum AUM in DI amount of S$20 million (for S13O/OA) or S$50 million (for S13U) subsequently?

What are the required procedures if an existing S13O/OA/U fund intends to change its fund manager from a non-SFO to an SFO, or vice versa?

Do changes in (a) beneficial owners of an S13O/OA/U SFO fund (or beneficiaries where the fund is structured as a trust), (b) shareholders, directors, key employees (C-suites) and investment professionals in the SFO, or (c) new intermediate entities in the holding structure of an S13O/OA/U SFO fund or SFO, need to be reported to MAS after the approval of the S13O/OA/U tax incentive?



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