Why Global Fund Managers Choose the Singapore VCC

A. Fund-native structure
Designed to operate as one or multiple collective investment schemes across open and closed-end strategies.

B. Flexible standalone or umbrella model
A VCC can run as a single fund or host multiple sub-funds under one shared governance framework.

C. Statutory sub-fund segregation
Each sub-fund is legally ring-fenced, preventing cross-liability between portfolios.

D. Privacy with regulatory access
Investor records remain private while fully accessible to regulators when required.

Regulatory and Governance Requirements for a VCC

Under ACRA’s framework, a VCC must meet the following core requirements:

• Permissible fund manager
  A VCC must be managed by an appointed permissible fund manager.
• Director requirements
  At least one director must be ordinarily resident in Singapore, and at least one director must be either a qualified representative or a director of the fund manager.
• AML/CFT compliance
  A VCC must comply with anti-money laundering and counter-terrorism financing obligations under the MAS regulatory framework, working with MAS-regulated financial institutions where required.

Tax Treatment and Reporting Framework

According to IRAS’ latest e-Tax Guide (3rd edition, 30 September 2025), the VCC tax framework includes:

• Corporate income tax
  A VCC is generally treated as a single company for income tax purposes, including umbrella structures unless otherwise specified.
• GST treatment
  Each sub-fund within an umbrella VCC may be treated as a separate taxable person for GST purposes due to its independent trading capacity.
• Stamp duty
  Sub-funds are treated as separate entities for stamp duty, with duties assessed at the sub-fund level in line with statutory asset segregation.

Typical VCC Structures

Option 1: Standalone VCC

• One VCC operates a single fund strategy or product,
• ideal for focused, single-portfolio structures.

Option 2: Umbrella VCC with sub-funds

• One VCC with shared governance hosts multiple sub-funds,
• each strategy legally segregated in assets and liabilities.

What Adepture Provides for VCC Projects

Structure design
Advisory on standalone vs umbrella models, sub-fund structuring, and service-provider/cost frameworks aligned with statutory segregation and tax treatment.

Incorporation and compliance setup
Full setup under ACRA requirements, including director and fund manager compliance configuration, filings and ongoing regulatory support.

Tax and transaction framework
Guidance on income tax, GST and stamp duty treatment based on IRAS guidelines.

Operational support
Sub-fund establishment and changes, coordination with auditors, corporate secretarial and fund administration providers, and governance documentation maintenance.