What happened
On 6 July 2026, MOF gazetted the Income Tax (Exemption of Income of Foreign Trusts) (Amendment) Regulations 2026, amending the section 13F (Foreign Trust Scheme) framework.
The amendment was enacted with retrospective effect from 1 January 2024:
- Widened scope of eligible trusts: clarifies that foreign trusts whose settlor or beneficiaries later become Singapore tax residents remain qualifying foreign trusts for a transition period.
- Alignment with section 10L: ensures that foreign trusts exempt under section 13F are shielded from section 10L capital gains taxes on foreign asset disposals.
- Eligible trustee companies: updates licensing standards for licensed Singapore trust companies acting as trustees of section 13F trusts.
Why it matters
Families frequently set up foreign trusts before immigrating to Singapore.
Previously, if a family member moved to Singapore, there was a risk that the trust would immediately lose its section 13F tax exemption, exposing the entire trust income and foreign capital gains to Singapore taxation. The retrospective widening provides certainty and protects existing trust structures established under foreign law.
What to do now
- Review the residency status of settlors and beneficiaries across all family trusts administered by Singapore trustees.
- Confirm that the trust deeds and accounting records satisfy the amended section 13F conditions.
- Ensure the licensed trust company completes annual compliance filings with IRAS before statutory deadlines.
Key resources
General information only; not tax or legal advice.