Wealth Management in Asia’s Power Trio: A Comparative Guide for Single Family Offices

As Asia strengthens its role as a global wealth center, ultra-high-net-worth individuals (UHNWIs) are increasingly establishing Single Family Offices (SFOs) to oversee private investments, succession planning, and philanthropic initiatives. Among the region’s top contenders, Malaysia, Singapore, and Hong Kong stand out for their robust financial infrastructure, favorable tax regimes, and supportive regulatory frameworks.

Selecting the right jurisdiction for an SFO involves more than just tax considerations—it requires a holistic assessment of regulatory requirements, setup costs, operational flexibility, access to talent, and long-term strategic alignment. While these financial hubs share some common advantages, each offers unique attributes that can shape how a family builds, preserves, and transfers its wealth across generations.

The table below provides a comparative snapshot of the key incentives, conditions, and regulatory landscapes for establishing a SFO in Malaysia, Singapore, and Hong Kong.

Criteria	Malaysia (Forest City SFO Scheme)	Singapore (MAS S130/13U Scheme)	Hong Kong (Family Office Regime)
Minimum AUM	RM 30m (~USD 6.9m)	SGD 20m (~USD 15m)	HKD 240m (~USD 32m)
Regulatory Body	Securities Commission Malaysia (SC)	Monetary Authority of Singapore (MAS)	Securities and Futures Commission (SFC)
SFO Structure	Dual-entity (SFOV in SFZ & SFO MC)	Single entity (Co. or Trust), Singapore incorporated	Corporate entity, activity-based licensing
Tax Rate	0% for 10 years initial +10 years extension	0% on qualifying income	0% on qualifying transactions under SFO tax concession
Min Operating expenses	RM500k (USD 115k)	SGD200k (USD 146k)	HKD 2m (USD 260k)
Employee Requirement	2 full time (1 investment professional)	2-3 investment professionals(at least 1 non-family member)	2 full-time qualified employees
Minimum Investment Professional Salary (Annual)	RM 120k (~USD 28k)	SGD 42k (~USD 33k)	Not specify. However, average salary of an investment professional is approximately HKD 1m (USD 127k).
Local investment requirement	10% of AUM or RM10m, whichever is lower	10% of AUM or SGD10m, whichever is lower	No requirement
Application and approval	Yes, with SC, which takes ~6 months to get approval	Yes, with MAS , which takes more than 12 months to get approval	No prior approval or application is required
Visa Application (for Foreign Applicant)	MM2H, Premium Visa Programme (PVIP)	Global Investor Programme (GIP), Employment Pass. EntrePass	Capital Investment Entrant Scheme (CIES), Entrepreneur Visa

Final Verdict: Choosing Your Family Office Home Base

1. For Primary Focus on Direct Tax Optimization:

• Consider Malaysia as the leading option. The Malaysian SFO Incentive Scheme directly

  accommodates a USD 6.9 million AUM, offering a 0% tax rate on qualifying income and capital gains for up to 20 years. This is a significant and immediate tax advantage that is not directly available at this AUM level in Singapore or Hong Kong's specific SFO incentive regimes.

• Evaluate commitment to local substance. The decision to establish in Malaysia should be accompanied by a genuine willingness to meet the local investment mandate and operational expenditure requirements, including establishing a physical office in Forest City SFZ and employing local professionals.

2. For Preference of a Highly Developed Financial Hub with Growth Potential

• Explore Singapore with a growth strategy. While Singapore requires a higher AUM as compared to Malaysia, Singapore offers a world-class financial ecosystem, robust regulatory oversight, and strong compliance infrastructure.

• Factor in higher operational costs and stringent compliance. Singapore's higher local business spending requirements and emphasis on AML/KYC checks by MAS-regulated financial institutions necessitate a significant operational budget and a proactive approach to compliance.

  
  

3. For Offshore Tax Efficiency

• Assess Hong Kong for its general territorial tax system. Under this regime, only income arising from or derived within Hong Kong is subject to tax, while foreign-sourced income—whether remitted or retained offshore—is fully exempt. This structure significantly enhances the tax efficiency of offshore investment activities conducted through a Hong Kong-based family office.

• However, the minimum AUM (~USD 32 million) and substance requirements mean this route is most beneficial for larger, well-structured family operations.

To explore the various family office and tax benefit options and how we may help you build your family’s multi-generational financial success. Start a conversation with us today at jamesyeoh@octave.com.my.