HighworthcitizenguyHenley & Partners projects 165,000 high-net-worth individuals will relocate internationally in 2026 — a 16% increase on the record 142,000 moves recorded in 2025. A disproportionate share of that capital is choosing between two Asian jurisdictions that now compete openly for the same families. Hong Kong recorded 3,384 single family offices at the end of 2025. Singapore’s Monetary Authority had granted incentive status to roughly 2,000 single family offices over the same period, up from about 400 in 2020. The headline numbers are not directly comparable, and the difference explains most of what matters.
By the High Worth Citizen Editorial Team
Key Takeaways
- Hong Kong counts 3,384 single family offices; Singapore has granted tax-incentive status to roughly 2,000 — a licensed subset, not a raw population count.
- Singapore’s Section 13O requires S$20 million in designated investments at application, with no ramp-up period since January 2025.
- Hong Kong’s FIHV regime offers a 0% concessionary profits tax rate above a HKD 240 million asset threshold, but government sources describe uptake as “relatively small”.
- Hong Kong’s New Capital Investment Entrant Scheme has drawn over 3,300 applications worth roughly HKD 99 billion since March 2024.
- The decision increasingly turns on political-continuity risk rather than headline tax rates.
The Tax Architecture Compared
Singapore operates two principal exemptions under the Income Tax Act. Section 13O carries a minimum of S$20 million in designated investments and is effectively the only route below S$50 million. Section 13U sits above that threshold and demands a larger operational footprint — more investment professionals, higher local business spending and stricter fund-residency conditions. Both deliver full exemption on qualifying investment income, in a jurisdiction with neither capital gains tax nor inheritance tax. The January 2025 reforms removed the ramp-up period, so the S$20 million must be committed at the point of application rather than built toward.
Hong Kong’s answer is the family-owned investment holding vehicle. An FIHV managed by an eligible single family office, meeting the HKD 240 million asset threshold and the substantial-activities test, pays a 0% concessionary profits tax rate on qualifying income. On paper this is the more generous regime. In practice, the Hong Kong government itself has described Schedule 16E uptake as relatively small — which is precisely why the Inland Revenue (Amendment) Bill published on 12 June 2026 proposes widening the qualifying-asset definition and easing the eligibility perimeter for FIHVs, funds and carried interest alike.
Residency and Mobility Pathways
Tax treatment and the right to live somewhere are separate questions, and families frequently conflate them. Hong Kong’s New Capital Investment Entrant Scheme, relaunched in March 2024 at a HKD 30 million investment threshold, had attracted nearly 3,200 applications worth about HKD 95 billion by end-February 2026, rising to over 3,300 applications and roughly HKD 99 billion shortly after. That is a functioning, high-volume investor migration channel; we covered its mechanics in our guide to Hong Kong’s Capital Investment Entrant Scheme.
Singapore’s equivalent — the Global Investor Programme — is deliberately narrower and more discretionary, and Singapore has not published comparable application volumes. Families generally arrive on Employment Pass or EntrePass routes tied to the family office entity itself, which is why the MAS incentive count and the residency count are so tightly coupled there. Our detailed treatment of Singapore’s family office regime for HNWIs sets out the substance requirements in full.
What This Means for HNWIs
Start by identifying which constraint actually binds. If the family’s assets sit between S$20 million and S$50 million, Singapore’s 13O is the only serious incentive route and Hong Kong’s HKD 240 million threshold — roughly S$40 million — may exclude you outright. Above that, both are live.
Second, model substance cost, not just the headline rate. Both regimes require local investment professionals, local spending and genuine management presence. A 0% rate on paper that requires a Hong Kong team you have no intention of hiring is more expensive than a Singapore exemption you can actually satisfy.
Third, treat the June 2026 Hong Kong bill as a live variable. If the widened perimeter passes as drafted, the arithmetic shifts in Hong Kong’s favour for families whose asset mix previously failed the qualifying-asset test. Families mid-decision should ask counsel to sequence the application against the bill’s passage rather than assume today’s rules.
Fourth — and this is the factor that most often decides it — assess political-continuity risk explicitly rather than implicitly. Hong Kong’s relationship with the mainland and the National Security Law are standing considerations in every advisory memo written on this question. Singapore’s counter-offer is constitutional continuity and an independent judiciary. Neither is a tax argument, and both belong in the model.
Country Comparison
Singapore: S$20m (13O) or S$50m (13U) entry, full exemption on qualifying income, no capital gains or inheritance tax, codified and published criteria, stricter substance since January 2025, narrower residency pathway. Hong Kong: HKD 240m entry, 0% concessionary profits tax, historically low uptake with reform pending, deep and high-volume investor-migration channel via the New CIES, closer proximity to mainland deal flow, higher perceived political risk. The pattern in practice: families prioritising mainland China access and migration throughput lean Hong Kong; families prioritising legal predictability and multi-generational continuity lean Singapore.
Risks and Considerations
Both regimes have tightened substance requirements within the last two years, and there is no reason to assume either has finished. Singapore’s removal of the ramp-up period stranded families who had planned a phased build. Hong Kong’s FIHV reform is a bill, not law, and drafting can change before passage. Neither incentive protects against home-jurisdiction exit taxes, controlled foreign company rules or treaty-based challenges to claimed residency — the most common point of failure is not the destination regime but the departure one. Currency exposure, reporting obligations under CRS, and the cost of maintaining genuine local management should all be underwritten before an application is filed.
The Bottom Line
Hong Kong offers the more generous headline regime and the deeper investor-migration channel; Singapore offers the more predictable one and, for most families, the easier substance test to actually satisfy. The June 2026 reform bill narrows the gap on tax, which pushes the decision further toward governance, continuity and where the family’s operating interests genuinely sit.
This article is for informational purposes only and does not constitute legal, tax, financial, or migration advice. HNWIs and family offices should consult qualified professionals in the relevant jurisdiction before making decisions based on the information presented.