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Singapore has launched a new corporate structure for the global investment fund industry, called the Variable Capital Company (VCC), providing fund managers with greater operational flexibility and cost savings. A grant scheme that helps managers reduce the costs of establishing a VCC has also been launched.

Fund managers will be able to form investment funds as VCCs across both traditional and alternative strategies, and as open-ended or closed-ended funds, whether as a stand-alone entity or an umbrella entity with multiple sub-funds. In addition, existing funds can be redomiciled to Singapore as VCCs.

Grants and Potential Tax Exemptions for VCCs

Managers are also able to take advantage of a VCC grant scheme that runs until 15 January 2023. The scheme will part-pay the costs of incorporating or registering a VCC by co-funding up to 70% of eligible expenses paid to Singapore-based service providers. The grant is capped at S$150,000 for each application, with a maximum of three VCCs per fund manager. In addition, a VCC may be able to benefit from Singapore's existing tax exemption schemes for funds, commonly referred to as Sections 13R and 13X, subject to meeting their requirements.

How We Can Help

We provide a full range of corporate and fund administration services and can assist with the formation of a new VCC structure or re-domiciliation to Singapore of an existing fund. Please contact Marilyn See for more information.

On 20 April 2020, the BVI International Tax Authority (ITA) extended the 2020 deadlines in the BVI for the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) as follows:

• FATCA enrolment deadline extended to 31 July 2020
• FATCA filing deadline extended to 31 August 2020
• CRS enrolment deadline extended to 30 June 2020
• CRS filing deadline extended to 31 July 2020

The Cayman Islands Tax Information Authority has issued updated Guidance Notes in relation to the jurisdiction’s economic substance legislation, replacing the previous Guidance.

In addition, amendments have been made to the Economic Substance Law, culminating in the International Tax Co-operation (Economic Substance) Law, 2020 as amended.

Please read our briefing and contact the Trident Cayman ES team with any questions at CaymanSubstance@tridenttrust.com.