The cost of a VCC has three layers. The first is the statutory fees charged by the Accounting and Corporate Regulatory Authority (ACRA), which are published and uniform. The second is the fees of service providers: the fund manager, fund administrator, custodian, auditor, company secretary, Eligible Financial Institution (EFI), lawyers and tax advisers, all set by market quotes. The third is the local business spending (LBS) a fund must incur once it applies for a fund tax incentive such as 13O / 13U; this is a condition for the tax exemption, not a fee paid to anyone. Only the first layer has official pricing, so for the second layer this page covers fee types and pricing methods only, and does not quote figures such as "typically from S$X0,000" that have no official basis.
Layer one: statutory ACRA fees
ACRA's Service and transaction fees (VCC) page (29 January 2026) lists the following VCC fees (in Singapore dollars):
| Item | Fee | Notes |
|---|---|---|
| Name application | S$15 | Reserves a name before incorporation or re-domiciliation |
| Registering a VCC | S$8,000 | S$8,015 including the name |
| Registering a sub-fund | S$400 each | For each additional sub-fund of an umbrella VCC; a sub-fund must be registered within 7 days of being established (VCC Act s 27(1)) |
| Re-domiciling as a VCC | S$9,000 + S$400 per sub-fund | Non-refundable |
| Extension for proof of deregistration (re-domiciliation) | S$200 each time | Each extension is 60 days |
| Filing the annual return | S$1,600 | Within 7 months after the financial year end |
| Extension of time for annual return or AGM | S$200 each time | Applied for separately |
| Application for exemption from accounting standards | S$200 | Application to be exempted from complying with accounting standards |
| Registration of a charge | S$60 | Registered within 30–37 days |
| Change of VCC or sub-fund name | S$15 | Other changes of particulars are free |
Worked example (hypothetical figures, for illustrating the calculation only): for an umbrella VCC with 3 sub-funds, the ACRA fees at incorporation are S$15 + S$8,000 + 3 × S$400 = S$9,215. ACRA's fee table lists the annual return at S$1,600 and does not state that it is charged per sub-fund; however, in an umbrella structure each sub-fund's accounts, assets and liabilities must be shown separately (ACRA, 16 March 2026), and the actual charge at filing is whatever ACRA's filing system applies.
Layer two: types of service-provider fees and how they are priced
Service-provider fees have no official benchmark and are quoted on top of the ACRA fees according to the scope of service and asset size. The table below covers only each role, whether it is legally required, and the usual pricing method:
| Service provider | Legally required? | Usual pricing method | What to clarify when getting a quote |
|---|---|---|---|
| Fund manager | Yes (must meet VCC Act s 46(2); a VCC cannot be its own manager) | Management fee as a percentage of NAV, sometimes with a performance fee; for a family that sets up its own management company, this shows up as that company's operating costs | Whether there is a minimum annual fee; whether each new sub-fund is charged separately |
| Fund administrator | Not mandated by law, but generally needed in practice | Percentage of NAV with a minimum annual fee; surcharge for more frequent valuation | Valuation frequency, number of investors, number of currencies |
| Custodian | A licensed manager must ensure independent custody | Custody fee based on asset size, with transactions charged per trade | Differences across asset classes such as listed securities, private equity and real estate |
| Auditor | Yes (appointed within 3 months; the small-company audit exemption does not apply) | Fixed annual fee, increased by number of sub-funds and complexity | Incremental audit fee for each sub-fund |
| Company secretary | Yes (appointed within 6 months) | Fixed annual fee | Whether AGMs, annual return filing and change filings are included |
| EFI (AML/CFT) | Yes | Fixed annual fee, increased by number of investors | How often due diligence is refreshed; how higher-risk investors are handled |
| Lawyers | Essentially required in practice at set-up | Fixed fee per project or hourly | Whether the constitution, offering documents and investment management agreement are covered by a fixed fee |
| Tax adviser | Usually needed when applying for a tax incentive | Per project or annual engagement | 13O / 13U application, annual declaration, income tax filing |
| Directors | A locally resident director is required by law | Annual directors' fees for independent directors | An authorised scheme needs at least 3 directors, at least 1 of them independent |
The audit, custody and independent valuation requirements come from regulation: a VCC must be audited every year and cannot use the audit exemptions in sections 205B and 205C of the Companies Act (ACRA Step 2, 29 January 2026); a licensed fund management company must ensure that assets are held by an independent custodian and independently valued (MAS SFA 04-G05 paragraphs 4.1.1 and 4.1.2); and an umbrella VCC must keep separate accounts for each sub-fund (VCC Act s 100(2)). These costs cannot be avoided even when there is only one family investor. MAS Circular IID 04/2025 (26 June 2025) also expects managers to regularly wind up VCCs that hold no assets or have no investors (as summarised by law firms); a dormant VCC still incurs annual costs.
Layer three: local business spending is a condition, not a fee
13O / 13U require a fund to incur a certain amount of local business spending in Singapore in every basis period. MAS Circular FDD Cir 05/2026 (31 July 2026) sets tiers by assets under management in designated investments (AUM in Designated Investments, AUM in DI):
| AUM in DI | Non-family-office funds (third-party money) | Single-family-office funds (awarded from 1 August 2026) |
|---|---|---|
| Below S$250 million | S$200,000 | S$200,000 |
| S$250 million to below S$2 billion | S$300,000 | S$500,000 |
| S$2 billion and above | S$500,000 | S$1,000,000 |
Further points: non-family-office funds may transition on total business spending of S$200,000 until YA 2028; family-office funds may offset part of the spending with qualifying donations and blended-finance grants, with grants counted at 2 times; closed-end funds may opt to compute LBS on a cumulative basis, and are exempt from the 11th award year. In its Q&A on closed-end funds (Annex 8A FAQ 3), MAS states that an umbrella fund is treated as one legal entity for the award, that LBS is aggregated across sub-funds, and that a new sub-fund does not constitute a new award; by inference this applies to umbrella funds generally, subject to MAS confirmation. Which expenses count towards LBS is governed by the circular's definitions.
Staffing conditions also belong in the budget: a qualifying investment professional must be a Singapore tax resident, earn more than S$3,500 a month and be substantively engaged in fund management (circular footnotes 13 / 18). The capital deployment requirement for family-office funds (investing the lower of 10% of AUM in DI and S$10 million in specified categories) is an investment allocation rather than a cost, but it does affect how assets are arranged. Existing funds follow the conditions of their original award letters and the transitional arrangements, as set out in MAS's written notification.
Does an umbrella structure spread the costs?
The fee advantage of an umbrella is the most obvious: the ACRA fee for an additional sub-fund is S$400, while a separate VCC costs S$8,015. The board, fund manager, company secretary and EFI can also be shared at umbrella level, spreading fixed costs across several sub-funds.
Tax filing also has economies of scale. IRAS's Tax Framework for VCCs (Fourth Edition, 22 April 2026) states at paragraph 2.1 that a VCC, umbrella or not, is treated as a single entity for income tax; paragraph 5.40 states that an umbrella VCC files only one set of income tax returns (it must use Form C; Form C-S / C-S Lite are not available), and IRAS need not be notified when a new sub-fund is set up.
But the savings have limits:
- Computation is still by sub-fund: an umbrella VCC's chargeable income is the sum of its sub-funds' income, and tax rules apply at sub-fund level; under current rules, unutilised capital allowances, losses and donations of a loss-making sub-fund cannot be set against a profitable sub-fund (IRAS Fourth Edition paragraph 5.9 and table notes).
- GST and stamp duty look at each sub-fund: for GST each sub-fund is treated as a separate person, and the same applies for stamp duty (paragraphs 2.2 and 2.4).
- Audit and valuation grow with the number of sub-funds: every sub-fund has its own accounts, and the audit and valuation work does not disappear because the umbrella is shared.
- Different asset classes make services hard to share: when sub-funds invest in different assets, custody and administration costs are also difficult to share.
- Winding up a sub-fund involves extra steps: tax clearance must be obtained from IRAS before a sub-fund is wound up (paragraph 5.41).
For structural details see Umbrella VCCs and sub-funds; for the tax treatment see VCC tax.
Ongoing costs: penalties, extensions and GST remission
Beyond annual service fees, ongoing costs include "the cost of getting it wrong" and "costs that can be recovered".
| Item | Amount or rule | Source and date |
|---|---|---|
| Annual return filed up to 3 months late | S$300 | ACRA penalties page, 23 June 2026 |
| Annual return filed more than 3 months late | S$600 | Same |
| Composition sum (e.g. late AGM) | Minimum S$500 per breach | Same |
| Fine on conviction for not filing the annual return within 7 months | Up to S$10,000 | ACRA penalties page, 23 June 2026 |
| Sub-fund not registered within 7 days | Fine on conviction of up to S$1,000 | VCC Act s 27 |
| Extension of time for annual return / AGM | S$200 each time; each annual return extension is 60 days | ACRA fee table and annual return page |
| 13O / 13U annual declaration not filed on time | No tax exemption for that year of assessment, and MAS may terminate the award | FDD Cir 05/2026 FAQ |
On the other side, qualifying funds can recover GST on expenses related to their investment activities under the GST remission (available until 31 December 2029, FDD Cir 05/2026 Annex 4), which reduces the effective burden of service fees; the conditions are covered in VCC tax.
The VCC Grant Scheme has ended
The VCC Grant Scheme (VCCGS) used to offset part of the set-up cost:
| Phase | Period and grant terms | Source |
|---|---|---|
| Initial | From 15 January 2020 for up to 3 years; up to 70% of qualifying expenses paid to Singapore-based service providers, capped at S$150,000 per VCC, for up to 3 VCCs per fund manager | Joint MAS and ACRA release, 15 January 2020 |
| Extension | Incorporations or re-domiciliations with an ACRA notification date from 16 January 2023 to 15 January 2025 inclusive; 30% of qualifying expenses, capped at S$30,000, limited to first-time fund managers | Allen & Gledhill, 7 February 2023 (secondary) |
As of 24 October 2026, this site has not found any announcement of a further MAS extension, so a VCC incorporated or re-domiciled after 15 January 2025 should not factor the grant into its cost estimates. If a service provider's quote still mentions that "the VCC grant can be applied for", ask for MAS's current documentation.
Checklist for comparing quotes
- Does the quote separate one-off set-up fees from annual fees, and does it list the incremental fee for each additional sub-fund?
- What are the minimum annual fees for fund administration and custody, and what is the surcharge for more frequent valuation?
- Is the audit fee quoted per sub-fund, and does it include the financial statements needed for the annual return?
- Does the company secretarial fee cover AGMs, annual return filing, sub-fund registration and changes of particulars?
- How does the EFI fee change with the number of investors and their risk rating?
- Are the adviser's fees for the 13O / 13U application, the annual declaration and income tax filing listed separately?
- Have local business spending and the cost of investment professionals been included in the annual budget of the family office or management company?
- Is every quote dated, with the currency and asset-size assumptions stated, and has the effect of the GST remission been taken into account?
For set-up steps and timing see Setting up a VCC; for annual obligations see Annual compliance checklist. If you need this interpreted for your own situation, you can register your enquiry through the contact details on this site.
Sources and dates
- Service and transaction fees (VCC) — ACRA · 2026-01-29
- Penalties & enforcement action (VCC annual returns) — ACRA · 2026-06-23
- Variable Capital Companies Act 2018, ss 97–100 (Part 8) — AGC (Singapore Statutes Online) · 2026-10-24 (accessed)
- Circular FDD Cir 05/2026: Tax Incentive Schemes for Funds — MAS · 2026-07-31
- IRAS e-Tax Guide: Tax Framework for Variable Capital Companies (Fourth Edition) — IRAS · 2026-04-22
- Guidelines on Licensing and Conduct of Business for Fund Management Companies (SFA 04-G05) — MAS · 2025-09-03
- MAS extends Variable Capital Companies Grant Scheme (law firm article, secondary) — Allen & Gledhill · 2023-02-07
- MAS and ACRA launch Variable Capital Companies framework — MAS · 2020-01-15