A booking centre is not a city of residence. It is the place where the family’s bank accounts, custody, and fund vehicles are booked, reported, and supervised. Singapore versus Hong Kong 2026 is therefore a comparison of two public architectures: the Monetary Authority of Singapore on one side, the Hong Kong Monetary Authority (and, for markets and some family-office tax files, the Securities and Futures Commission and the Inland Revenue Department) on the other. It is not a brochure about moving house, schools, or passports.
This article is general information for families and family offices. It is not a mandate, a licensing opinion, or personalised advice. Where a vehicle may be booked depends on facts, on the supervisors’ rules in force, and on counsel. Vellum Finance does not sell either city.
Singapore versus Hong Kong 2026 as a booking question
Families confuse three maps. The first is tax residence of individuals. The second is the place of effective management of a holding or a fund. The third is the booking location of cash, securities, and loans: which licensed bank holds the account, which supervisor can inspect it, and which AML file the relationship actually lives in. This note is about the third map, with enough of the second to explain why 13O, 13U, and Hong Kong’s family-owned investment holding vehicle concession exist. The first map belongs in a residence file, including whatever analog regime the family is still quoting.
Both cities remain international banking centres. Both have English-language courts and a deep bench of private banks. Both tightened family-office frameworks after a wave of inbound SFOs. The useful 2026 question is not “which hub won.” It is which supervisor, which tax concession, and which substance test the family’s actual booking would have to satisfy.
MAS: banking licence, fund tax schemes, and the SFO file
The Monetary Authority of Singapore is the integrated supervisor: central bank, banking supervisor, and capital-markets regulator. A family that books a private-bank account in Singapore books it with an MAS-licensed institution. That is the first operational fact. MAS also administers, with the tax authority, the fund tax incentive schemes that many single family offices actually come for.
The MAS page on fund tax schemes for family offices sets out sections 13O, 13OA, and 13U of the Income Tax Act 1947. In outline, a fund vehicle managed by a Singapore-based manager, including a family office, can obtain a tax exemption on specified income if it meets the scheme conditions throughout the incentive period. The published grid still distinguishes a lower AUM gate for 13O/13OA (S$20 million in designated investments) from 13U (S$50 million), with a minimum number of investment professionals of whom at least one is not a family member, a private-banking account with an MAS-licensed institution, and a local business-spending test, including a capital-deployment requirement toward specified Singapore and climate-related assets. Those numbers are MAS’s own table. They are conditions, not a marketing package. Families who “round to twenty million in a holding somewhere” have not met designated investments at the point of application and throughout the period.
MAS also publishes FAQs on the schemes for single family offices. Changes in beneficial owners, directors, key employees, and intermediate entities after approval are not private. They are to be notified. Swapping a licensed fund-management company for an SFO as manager changes the economic conditions. The 2026 baseline is that the concession is a supervised exemption, not a silent flag on a term sheet.
Separately, MAS has moved single family offices toward a class licensing-exemption framework, with a notice of commencement of business and ongoing conditions, including bank accounts with MAS-licensed banks for the SFO and its Singapore-incorporated fund vehicles. Families arriving in 2026 should read the MAS exemption FAQs in force, not a 2019 “SFO is unregulated” dinner story. Notification is not a substitute for the 13O/13U tax file. It is a different drawer: permission to manage the family’s money without a full fund-management licence, on conditions.
HKMA: the banking book, with IRD and SFC in the next rooms
Hong Kong’s architecture is split. The Hong Kong Monetary Authority is the banking supervisor and the monetary authority. A family that books cash, custody, and credit in Hong Kong books them in an HKMA-supervised authorized institution (or in a registered institution for some securities activities, where the SFC’s overlay also bites). That split is the first high-level difference from MAS. There is no single “HKMA family-office licence” that replaces both banking and markets. Families who ask “what does HKMA think of our SFO” are often asking the wrong supervisor for the tax concession and the wrong supervisor for discretionary management.
The family-office tax concession sits with the Inland Revenue Department. The IRD page on tax concessions for family-owned investment holding vehicles describes the Inland Revenue (Amendment) (Tax Concessions for Family-owned Investment Holding Vehicles) Ordinance 2023, in force from 19 May 2023 and applying to years of assessment commencing on or after 1 April 2022. Eligible FIHVs managed by an eligible single family office in Hong Kong, and family-owned special purpose entities, can meet a profits-tax concession (a 0% rate) on assessable profits from qualifying transactions and from incidental transactions within a 5% threshold. The FIHV must be normally managed or controlled in Hong Kong. The SFO must meet an asset-size threshold (HK$240 million is the figure the IRD and the government use in public explanations) and substantial-activity tests (qualified employees and operating expenditure in Hong Kong). There is no MAS-style pre-approval of a numbered scheme. Eligibility is claimed, typically with an annual declaration. Anti-avoidance and associated-person rules exist. This article does not invent 2026 AUM league tables for Hong Kong SFOs.
Markets conduct, offering of securities, and whether an SFO needs an SFC licence remain SFC questions. A booking centre that is “only a bank account” can still become a regulated activity if the Hong Kong office holds itself out as managing third-party money, or if the FIHV’s “incidental” dealing exceeds the concession’s design. HKMA cares that the bank knows its customer. IRD cares that the FIHV earns qualifying profits under the ordinance. SFC cares about regulated activity. Three rooms.
What “booking” means in a multi-entity family
Booking is a ledger fact. Which entity is the account holder? Which law governs the custody agreement? Which supervisor can demand the KYC file? Where are the books of the fund vehicle? A family can live in Europe, hold a Luxembourg SOPARFI, and still book the liquid portfolio in Singapore or Hong Kong. That structure is common. It is also how families discover that the concession they wanted (13U, FIHV) requires people, spend, and control in the Asian city, while the people actually sit in Europe. The concession then fails, and the booking remains, now as an ordinary taxed fund or an ordinary company with a private-bank account.
Substance, AML, and why the brochure is not the file
Both hubs now sell substance in public. Singapore’s 13O/13U grid counts investment professionals, local spend, and designated investments. Hong Kong’s FIHV concession counts employees, operating expenditure, and central management or control. A brass-plate office with a visiting director will struggle in both. That is the 2026 baseline, not a moral judgement.
AML is the other shared floor. MAS-licensed banks and HKMA-authorized institutions both run FATF-aligned onboarding. Beneficial-ownership chains, source of wealth, and sanctions screening are slower than they were in the 2010s. A family that wants a booking centre because “the other one asked too many questions” will meet the same questions after a few months. Cross-border succession and reporting already sit in live Vellum notes such as inheritance-tax rules by country in 2026; CRS and bank files feed the same map.
Open architecture still matters once the account exists. A Singapore or Hong Kong private bank can be a superb custodian and still run a guided list. The 2026 independence test in the open-architecture versus in-house funds note does not change with the skyline. Booking location and product factory are different conflicts.
A practical comparison without a relocation pitch
Supervisor: MAS is integrated. Hong Kong splits HKMA, SFC, and IRD. Families who want one counterpart for banking-plus-fund-exemption conversations often find Singapore’s map easier to draw. Families who already bank in Hong Kong, trade China and US dollar markets through Hong Kong infrastructure, and can staff an office that is actually managed there, often keep the booking where the operating relationships already are.
Tax concession: Singapore’s 13O/13U is an application to MAS with ongoing economic conditions and designated-investment tests. Hong Kong’s FIHV is a profits-tax concession claimed at IRD, with a HK$240 million asset threshold and substantial-activity tests, without that numbered pre-approval. Neither concession is a personal income-tax holiday for the principals. Individual residence remains a different statute in each place, and a different statute again in Europe.
Vehicles: Singapore’s variable capital company and ordinary Singapore companies are common fund wrappers under 13O/13U. Hong Kong uses companies and other entities as FIHVs, including vehicles established outside Hong Kong if they are normally managed or controlled there. “We incorporated in BVI, so we are not in Hong Kong” is not an answer if central management is in Hong Kong, and it is not an answer if the family wanted the concession.
Credit and custody: both HKMA and MAS supervise large private banks. Lending against a securities book, foreign exchange, and USD clearing follow the bank’s group, not the skyline slogan. Families should inventory which group, which booking branch, and which ring-fence they actually have, the same way they inventory a French holding’s interest limitation in other files.
Vellum’s role is to keep those inventories honest. The services map is fee-only coordination among counsel, banks, and the family’s own office, not a pitch to “move the book to Asia.” A booking centre that cannot be explained in one page (entity, supervisor, concession, people, bank) is not a centre. It is a correspondence account with a story.
Conclusion
Singapore versus Hong Kong in 2026 is a booking-centre comparison: MAS as an integrated supervisor with published 13O/13U conditions, versus HKMA as the banking supervisor beside an IRD family-office concession and an SFC markets overlay. Both demand substance. Neither is a residence product. Families who map accounts, vehicles, and people against the official pages will know which city can actually book the file. Families who buy a skyline will book a story, then meet the supervisor.
Discretion. Stability. Prosperity.
Team Vellum
A team of passionate professionals who combine their expertise to bring knowledge through Vellum Finance & Patrimoine blog articles. Each member writes about their own field of expertise, cross referencing with our colleagues own fields to ensure the highest quality of information possible in all our content.
