I OVERVIEW OF RECENT ACTIVITY
Global economic activity has slowed down considerably in recent times. The escalation of US-China trade tensions, macroeconomic stress in Argentina and Turkey, disruptions to the German auto sector, and tighter credit policies in China have all contributed to this decline. The International Monetary Fund projects that the rate of global growth is likely to fall to 3.3 per cent in 2019, down from 3.6 per cent in 2018.2
Amid the global slowdown, the investment outlook in Asia remains sanguine as assets under management (AUM) in Asia-Pacific is expected to outpace other regions by almost doubling from US$15.1 trillion in 2017 to US$29.6 trillion in 2025.3 Singapore will greatly benefit from this trend given its role as a financial node in the region.
Singapore has always enjoyed a sterling reputation for being an investor and business-friendly jurisdiction, in view of its political stability, efficient government, excellent infrastructure and communications systems and skilled work force.4 In the asset management space, the Singapore government takes a proactive role in encouraging the growth of the industry and has, over the years, introduced various attractive schemes, incentives, laws and regulations to promote such growth.
Based on the 2017 Singapore Asset Management Survey (the 2017 Survey) conducted by the Monetary Authority of Singapore (MAS), as at the end of 2017, total assets managed by Singapore-based asset managers grew strongly by 19 per cent to S$3.3 trillion (approximately US$2.4 trillion),5 compared to S$2.7 trillion (approximately US$1.96 trillion) as at the end of 2016; this has outpaced the five-year average AUM growth rate of 15 per cent per annum, underscoring the strength of the asset management industry in Singapore, against the backdrop of an anaemic global economic environment.
More recently, the Singapore government introduced a new legal framework, the Variable Capital Companies Act (the VCC Act), to encourage investment funds to domicile in Singapore. The VCC Act introduces a new corporate entity that is tailored for investment funds (VCC) and is expected to come into effect in the second half of 2019. The VCC addresses a key weakness in the current fund regime, which lacks a variable fund structure to cater to the specific needs of certain types of funds. If the VCC structure is well received, Singapore will be able to capture a greater share of the full value chain of fund management, especially in the fund servicing space6 and enjoy a growth in fund inflows through new product ranges created and managed in Singapore.7
II GENERAL INTRODUCTION TO THE REGULATORY FRAMEWORK
Fund management is one of the 'regulated activities'8 regulated under the Securities and Futures Act, Chapter 289 of Singapore (SFA). Fund management is defined under the SFA as managing the property of, or operating, a collective investment scheme, or undertaking on behalf of a customer (whether on a discretionary authority granted by the customer or otherwise) (1) the management of a portfolio of capital markets products, or (2) the entry into spot foreign exchange contracts for the purpose of managing the customer's funds, but does not include real estate investment trust management.
A corporation that carries on business in fund management in Singapore is prima facie required to hold a capital markets services licence (CMS licence) for fund management under the SFA (and its staff who conduct the regulated activities must be individually notified as representatives under the Representative Notification Framework), unless one of the exemptions under the SFA can be invoked.
Fund management companies (FMCs) operating in Singapore will have to fall under one of the following two categories:
- Registered FMCs (RFMCs): these are FMCs whose AUM do not exceed S$250 million, and who carry on business in fund management for not more than 30 'qualified investors', of which not more than 15 are funds (including funds structured as limited partnerships). The underlying investors of such funds will have to be accredited investors or institutional investors, or both (each as defined under the SFA). RFMCs will operate under a registration regime, and will be able to commence business in fund management after the MAS has published the registration of the RFMC on its website.
- Licensed FMCs (LFMCs): these are FMCs that hold a CMS licence for fund management. LFMCs are divided into A/I LFMCs who carry on business in fund management with 'qualified investors' only, with no restriction on the number of 'qualified investors'; and Retail LFMCs who may carry on business in fund management with all types of investors.
All FMCs are required to meet certain competency, business conduct and capital requirements. The following is a brief summary of some key points:
- Singapore incorporated: an FMC should be a Singapore incorporated company with a permanent physical office in Singapore.
- Base capital: an FMC must at all times meet the base capital thresholds, which range from S$250,000 to S$1 million depending on the type of fund management activity that is carried out. An FMC is encouraged to maintain an additional capital buffer over and above the requisite base amount.
- Risk-based capital: at all times, an LFMC has to meet the risk-based capital requirement and ensure that its financial resources are at least 120 per cent of the operational risk requirement.
- Competency requirements: an FMC should ensure that its staff who conducts fund management, and other regulated activities integral to fund management, has relevant experience and meet applicable entry and examination requirements (if applicable). An FMC should also satisfy the MAS that its shareholders, directors, 'representatives' (as defined under the SFA) and employees, as well as the FMC itself, are 'fit and proper'.
- Compliance arrangements: an FMC needs to have in place compliance arrangements that are commensurate with the nature, scale and complexity of its business. Ultimate responsibility for compliance with applicable laws and regulations rests with the FMC's CEO and board of directors, even though compliance support may be provided by a foreign related entity or third-party service providers, or both.
- Risk management framework: an FMC has to put in place a risk management framework that identifies, addresses and monitors the risks associated with customer assets and which is appropriate to the nature and size of its operations, and nature and complexity of the assets it manages. The risk management function should be segregated from and independent of the portfolio management function and all pertinent risks associated with customer assets should be identified and measured. The FMC should also develop and maintain procedures to ensure that these identified risks are closely monitored and that management is kept informed of risk exposures on a continual and timely basis. All policies, procedures and reports relating to the risk management function should be properly documented and maintained.
- Internal audit: the business activities of an FMC must be subject to adequate internal audit. The internal audit may be conducted by the internal audit function or outsourced.
- Independent annual audits: an FMC must meet the annual audit requirements set out in the SFA and Securities and Futures (Licensing and Conduct of Business) Regulations. The MAS may direct the FMC to appoint another auditor if the appointed auditor is deemed to be unsuitable, having regard to the scale, nature and complexity of the FMC's business.
- Professional indemnity insurance (PII): the MAS may impose a licence condition requiring a retail LFMC to obtain PII that meets with specified minimum requirements. A/I LFMCs and RFMCs are strongly encouraged to maintain adequate PII coverage. An FMC should disclose to all customers, both potential and existing, its PII arrangements or the absence of such arrangements.
- Letter of responsibility: where appropriate, the MAS may require an LFMC to obtain a letter of responsibility from its parent company.
- Independent custody: an FMC must ensure that the assets it manages are subject to independent custody. Independent custodians include prime brokers, depositories and banks that are regulated in their respective jurisdictions. This requirement does not apply in relation to (1) capital markets products that are not listed for quotation or quoted on an organised market, and (2) interests in a closed-end fund where the closed-end fund is to be used for private equity or venture capital investments and interests in the closed-end fund are offered only to accredited investors or institutional investors (and the FMC has made certain disclosures to the customer and obtained their acknowledgement).
- Independent valuation: an FMC must ensure that the assets it manages are subject to independent valuation and customer reporting. The independent valuation may be conducted by a third-party service provider (e.g., a fund administrator or custodian) or performed by an in-house fund valuation function that is segregated from the investment management function.
- Mitigating conflicts of interest: an FMC has to mitigate any actual or potential conflict of interest that may arise from the management of assets and where appropriate, disclose such conflict to the customer.
- Disclosure: an FMC should ensure that there is adequate disclosure to its customers in respect of each fund or account that it manages. Information that should be disclosed includes, among others, the investment policy and strategy and the risks associated with the strategy, the valuation policy and performance measurement standards, and the use of leverage. Disclosure should be made not only on a periodic basis, but as and when material changes occur.
On 20 October 2017, a new regulatory framework applicable to venture capital FMCs (VCFMs) came into effect. Although VCFMs are considered to be LFMCs, VCFMs are exempted from various requirements applicable to LFMCs, such as base capital, risk-based capital and compliance arrangements, resulting in a much shorter and simpler application process.
III COMMON ASSET MANAGEMENT STRUCTURES
Funds established in Singapore typically take one of three forms: the limited liability company, the limited liability partnership and the unit trust. A fourth form will be introduced when the VCC Act comes into force in the second half of 2019. The salient features of each of these vehicles are discussed below.
The incorporation and management of companies in Singapore is governed by the Companies Act, Chapter 50 of Singapore and regulated by the Accounting and Corporate Regulatory Authority. Companies limited by shares can be public or private, with the key difference being that a public company may have more than 50 shareholders and is subject to greater regulation than a private company. The advantage of a company is that it has a separate legal personality which allows its shareholders to enjoy limited liability protection. The disadvantage would be that there is a higher level of statutory regulation applicable to companies such as restrictions on the return of capital to shareholders.
ii Limited partnerships
The limited partnership is a well-established fund vehicle in many fund jurisdictions. In Singapore, limited partnerships are governed by the Limited Partnerships Act, Chapter 163B. A Singapore limited partnership must consist of at least one limited partner and one general partner, who may be either individuals or corporations. A general partner is liable for all debts and obligations of the limited partnership incurred while it is a general partner in the limited partnership. A limited partner, on the other hand, will generally not be liable for the debts and obligations of the limited partnership beyond the amount of its agreed contributions. The limited partnership is a natural framework for a fund structure as it is tax transparent, provides limited liability for investors and provides for the relative ease of cash repatriation even in the absence of profits. However, as a limited partnership does not have separate legal personality, to be afforded the benefit of limited liability, limited partners must not take part in the management of the limited partnership.
iii Unit trusts
A unit trust is a trust arrangement whereby the legal ownership of the scheme's assets is vested in a trustee who holds those assets on trust for the benefit of unitholders. A unit trust is constituted by an instrument of trust usually between a manager and a trustee. The trust instrument typically governs the appointment and retirement of the trustee and manager, their respective duties, distribution or accumulation of trust income, investment powers, dealing and valuation. The applicable legislation with regard to trusts in Singapore is the Trustees Act, Chapter 337 of Singapore. A unit trust structure, being largely contractual, is fairly flexible. Like a limited partnership, it is tax transparent and can provide limited liability for investors as well as relative ease of cash repatriation even in the absence of profits. One disadvantage of a unit trust is that it does not have separate legal personality. The requirement to have a trustee may also add costs to the structure and investors in certain jurisdictions may not be very familiar with such a structure.
iv Variable capital companies (VCCs)
The VCC is an upcoming corporate structure solely made for investment funds. The VCC can be set up as a single standalone fund or an umbrella fund with two or more sub-funds. The VCC addresses the limitations of the existing fund structures and introduces in Singapore a structure comparable to that of other leading international fund domiciles such as Luxembourg and Dublin. For instance, a VCC can issue and redeem shares without the need for shareholder approval and pay dividends out of capital. This is not possible for companies incorporated under the Companies Act. Another key advantage is that a VCC constituted as an umbrella fund enjoys economies of scale as the sub-funds therein can share a common board of directors and service providers.
IV MAIN SOURCES OF INVESTMENT
According to the 2017 Survey,9 78 per cent of total AUM attributable to Singapore FMCs was sourced from outside Singapore, demonstrating Singapore's primary role in serving regional and international investors. In 2017, the percentage of assets invested in equities rose from 42 per cent to 44 per cent, led by increased investments into Asia-Pacific and North America while investment into bonds pared by 2 per cent to 21 per cent, with outflows seen broadly across all regions. Allocations in other asset classes such as collective investment schemes, cash/money markets and alternative investments remained relatively unchanged since the past year at about 4–21 per cent for each class.
According to the same survey, for several years, the Asia-Pacific region has been the key investment destination for Singapore-based asset managers, accounting for 67 per cent of total AUM in 2017, a slight increase from 66 per cent in 2016. The relatively stable numbers reflect continued strong investor interest in the region.
V KEY TRENDS
Over the past few years, there has been an increase in both the number of asset managers being set up in Singapore and the AUM of Singapore asset managers, especially in relation to private equity investments. As at the end of 2017, total assets managed by Singapore-based asset managers stood at S$3.3 trillion (approximately US$2.4 trillion), representing a five-year average AUM growth rate of 15 per cent per annum.
Asset managers also continue to view Singapore as a conducive place to conduct portfolio management activity. In 2017, there was a net increase of 55 registered and licensed fund managers, bringing the total number of registered and licensed fund managers to 715.10 As the Asia-Pacific continues to be the fastest-growing region in the world,11 Singapore's position as one of the leading asset management hubs globally is expected to strengthen.
Even with the uncertainties in the global economy that arise from time to time, many expect the trend of growth in Singapore's asset management industry to continue in view of the relative economic stability and reputation as a safe haven. Going forward, Singapore is likely to benefit from greater offshore inflows from China as Chinese HNWIs increasingly prefer to book their assets in Singapore over Hong Kong. Crucially, Singapore is less proximate to the Chinese authorities, which brings the wealth of these Chinese HNWIs out of China's reach.12 This key advantage that Singapore has over Hong Kong was in the spotlight recently after a reported increase in interest in movement of funds from Hong Kong to Singapore following concerns over a proposed bill to allow the extradition of suspects from Hong Kong to face trial in China.13
The global trend towards economic substance has and will continue to push Singapore to the forefront as asset managers move away from the traditional offshore tax havens. The various factors and strengths of Singapore carefully developed and built up over time including the robust business infrastructure coupled with Singapore's reputation as the place with the highest quality of living in Asia14 will continue to attract asset managers to strongly consider Singapore as a place to locate, making the MAS' emphasis on economic substance an easier pill to swallow. The extensive network of double taxation treaties that Singapore has entered into also adds to the attraction of using Singapore as a fund domicile.
VI SECTORAL REGULATION
Insurance asset management is regulated under the general fund management regulatory regime.
Pension fund management is regulated under the general fund management regulatory regime.
iii Real property
A fund manager is exempt from the requirement to hold a CMS licence to carry on fund management if it carries on business in fund management in Singapore on behalf of 'qualified investors' where the assets managed by it comprise securities issued by one or more corporations or interests in bodies unincorporate, where the sole purpose of each such corporation or body unincorporate is to hold, whether directly or through another entity or trust, immovable assets.
iv Hedge funds
Hedge fund management is regulated under the general fund management regulatory regime.
v Private equity
Under the general fund management regulatory regime, an FMC must ensure that the assets it manages are subject to independent custody. Independent custodians include prime brokers, depositories and banks that are regulated in their respective jurisdictions.
The MAS recognises that for private equity and venture capital investments, independent custody may not be appropriate in all circumstances, hence the MAS allows this requirement to be waived for FMCs that manage closed-end private equity or venture capital funds (involving capital markets products that are not listed for quotation or quoted on an organised market).
VII TAX LAW
i Tax treaties
Singapore's comprehensive tax treaty network coupled with a relatively low corporate tax rate of 17 per cent is highly attractive to many multinational corporations including fund management companies and fund companies looking to establish a presence here. Additionally, the Singapore government has introduced a wide range of tax concessions and incentives to promote Singapore as a hub for financial services activities, and in particular the fund management industry.
As of June 2019, Singapore had approximately 85 comprehensive avoidance of double taxation agreements (DTAs) (agreements that generally cover all types of income), seven limited treaties (agreements that cover only income from shipping or air transport, or both) and seven treaties that are signed but not ratified (either comprehensive agreements or limited treaties that are not ratified and therefore do not have the force of law).15
DTAs between Singapore and another country not only serve to prevent double taxation of income, they also clarify the taxing rights between Singapore and the treaty partner on different types of income arising from cross-border economic activities between the two countries. In some circumstances, the agreements also provide for reduction or exemption of tax on selected types of income.
ii Singapore's tax regime for funds
In Singapore, income tax is a tax on income and there is no capital gains tax.
Singapore follows a territorial basis of income taxation. In other words, Singapore income tax is imposed on income accruing in or derived from Singapore. On the other hand, foreign-sourced income will generally not be taxable in Singapore, unless it is received or deemed to be received in Singapore under local income tax legislation.
Certain foreign-sourced income may be exempt from tax when received in Singapore by a Singapore tax resident. For example, foreign-sourced dividends are exempt from tax if the dividends or the underlying profits from which the dividends are paid have been subject to foreign tax and the headline tax rate in the foreign country is at least 15 per cent. Certain concessions and clarifications have also been announced by the Inland Revenue Authority of Singapore with respect to the above conditions.
Income derived by a fund that is managed in Singapore is generally regarded as Singapore-sourced and therefore subject to Singapore income tax.
In line with the government's effort to develop the fund management industry in Singapore and to promote and enhance Singapore's attractiveness as a fund management hub, various tax exemption schemes have been introduced over time to ensure that there is no tax disincentive for a fund to be managed in Singapore. The main tax incentive schemes are listed below and will be discussed briefly in this section:
- tax exemption under Section 13CA of the Income Tax Act, Chapter 134 of Singapore (ITA) (the Qualifying Fund Scheme);
- tax exemption under Section 13R of the ITA (the Resident Fund Scheme);
- tax exemption under the Enhanced-Tier Fund Scheme under Section 13X of the ITA (the ETF Scheme); and
- concessionary tax rate for FMCs that have been granted the Financial Sector Incentive (Fund Management) Award (the FSI-FM Award).
iii Offshore fund regime – Qualifying Fund Scheme
An offshore fund managed by a Singapore-based fund manager will be exempt from tax on 'specified income' from 'designated investments' if the fund is a qualifying fund. To be a qualifying fund in general, a fund cannot be a tax resident in Singapore.
In broad terms, 'specified income' covers income and gains in respect of 'designated investments'. The list of 'designated investments' includes most types of investment – for example, stocks, shares and securities. Immovable property in Singapore is excluded from the list.
Even if the fund is a qualifying fund, its investors must still be qualifying investors to avoid being taxed on their share of the fund's income and gains. Generally, Singapore-resident or Singapore-based corporate entities that beneficially own, alone or with their associates, more than 30 per cent (or 50 per cent if the fund has 10 or more investors) of the total value of the issued securities of the qualifying fund will be deemed to be non-qualifying investors. A non-qualifying investor is required to pay an amount to the Singapore tax authorities – effectively the corporate income tax on its share of the income and gains of the fund.
iv Resident Fund Scheme
The Resident Fund Scheme was introduced to encourage fund managers to base their fund vehicles in Singapore by giving them the same tax exemptions that are given to the qualifying offshore funds described above. The main advantage that a Singapore resident fund has over an offshore fund is its access to Singapore's large tax treaty network, covering more than 85 countries. The exemption is subject to approval by the MAS and there are additional conditions to be satisfied under the Singapore resident fund scheme. In particular, the fund vehicle must be a Singapore tax-resident company and must have an expenditure of S$200,000 or more in each financial year. A Singapore-based fund administrator must also be appointed.
Similarly to the Qualifying Fund Scheme, under the Resident Fund Scheme, 'specified income' in respect of any 'designated investments' derived by an approved Singapore resident fund is exempt from Singapore income tax.
To qualify for the Singapore resident fund scheme, an application must be submitted to the MAS on or before 31 December 2024. Once a fund is approved under the scheme, the tax exemption period is indefinite, subject to the fund continuing to meet all conditions for the scheme.
As with the Qualifying Fund Scheme, investors of an approved Singapore resident fund that are non-qualifying investors are liable to corporate income tax on their share of the income and gains of the fund.
v Enhanced-Tier Fund Scheme
Introduced with effect from 1 April 2009, the ETF Scheme provides greater flexibility to fund managers in sourcing their mandates. Fund vehicles that satisfy the conditions for the scheme must submit an application to the MAS by 31 December 2024.
Unlike the Qualifying Fund Scheme and the Resident Fund Scheme, the ETF Scheme does not limit the percentage of the investments in an approved fund that may be held by persons in Singapore. In addition, the type of fund vehicle and place of tax residence of the fund vehicle are generally not relevant conditions under the scheme.
As with the Resident Fund Scheme, MAS approval is required under the ETF Scheme. The criteria for approval to be granted include, but are not limited to:
- a minimum fund size of S$50 million at the time of application;
- at least S$200,000 of local expenditure for each financial year; and
- the Singapore-based fund manager managing or advising the fund employing at least three investment professionals in Singapore.
Provided they meet the required conditions, funds approved under the ETF scheme are granted tax exemption on 'specified income' in respect of any 'designated investments' for the life of the fund (similar to the Qualifying Fund Scheme and the Resident Fund Scheme).
In 2010, the ETF Scheme was amended to include a master-fund structure in the application framework. If a master-feeder fund structure is adopted and the feeder funds that invest solely in the master fund do not trade, the structure as a whole need only meet one set of economic conditions. 'Economic conditions' refers to:
- the minimum fund size of S$50 million at the point of application; and
- the minimum local business spending of S$200,000 for each fund in each basis period relating to any year of assessment.
The remaining non-economic conditions for the ETF Scheme will continue to apply to each master and feeder fund entity. However, if the feeder funds invest solely in the master fund and these feeder funds trade, the master-feeder structure as a whole must meet the sum of the economic conditions and commitments expected from each fund entity to satisfy the conditions under the scheme.
In 2015 the ETF Scheme was further extended to master-feeder-special purpose vehicle (SPV) fund structures to extend to SPVs established by the approved fund. Additional conditions under such extended scheme include the following:
- the master fund must be a Singapore entity and is regarded as a Singapore tax resident for each basis period; and
- the economic conditions must be met on a multiple-fold basis, depending on the number of SPVs.
Fund management incentive
The FSI-FM Award aims to promote fund management activities in Singapore. This incentive provides a concessionary tax rate of 10 per cent for fund management and investment advisory services provided to incentivised funds. 'Incentivised funds' are funds that rely on one of the tax exemption schemes for fund management (e.g., a fund relying on the Qualifying Fund Scheme or a fund approved under the Resident Fund Scheme or the ETF Scheme). For new applicants engaged only in the fund management or investment advisory services, the qualifying criteria include the following:
- the applicant must be licensed or exempt from having a CMS licence in respect of its fund management or investment advisory activities; and
- the applicant must have a minimum AUM of at least S$250 million.
The MAS may also take into consideration other qualitative factors – such as growth targets in terms of AUM, business spending and the number of investment professionals – when assessing the eligibility of the applicants for the FSI-FM Award.
Once a fund manager receives the FSI-FM Award, it must submit an annual review return to the MAS within four months of the end of its financial year.
The FSI-FM Award usually runs for a fixed period from the approval date. The fund manager must renew it with the MAS before it expires. In assessing whether to renew the FSI-FM Award, the MAS examines the incremental economic contributions (e.g., incremental headcount, business spending, value added) that would be made by the fund manager to Singapore's economy.
The global trend towards economic substance will see more interest to set up FMCs as well as funds in Singapore. The upcoming VCC fund structure will also give a boost to Singapore's fund management industry as it complements and expands on the existing suite of fund structures available in Singapore. This will provide investors with a comprehensive range of fund structures to support their needs.
All this comes at an opportune time as the AUM in the Asia-Pacific is expected to grow rapidly over the new few years and Singapore will be well positioned to capture this growth with its enhanced fund ecosystem.
1 Danny Tan is a partner at Allen & Gledhill LLP.
2 International Monetary Fund, 'World Economic Outlook: Growth Slowdown, Precarious Recovery' (2019) < https://www.imf.org/en/Publications/WEO/Issues/2019/03/28/world-economic-outlook-april-2019 accessed 21 June 2019.>
3 PricewaterhouseCoopers, 'Asset & Wealth Management 2025: The Asian Awakening' (2019) < https://www.pwc.com/sg/en/publications/asset-management-2025-asia-pacific.html> accessed 21 June 2019.
4 Deloitte, 'Taxation and Investment in Singapore' (2017) < https://www2.deloitte.com/content/dam/Deloitte/.../Tax/dttl-tax-singaporeguide-2017.pdf.> accessed 21 June 2019.
5 Monetary Authority of Singapore, '2017 Singapore Asset Management Survey: Asian Hub for Fund Management and Domiciliation' (2017) < http://www.mas.gov.sg/~/media/MAS/News%20and%20Publications/Surveys/Asset%20Management/2017%20AM%20Survey%20Report.pdf> accessed 21 June 2019.
6 Monetary Authority of Singapore, 'Variable Capital Companies Bill (2018) – Second Reading Speech by Ms Indranee Rajah, Second Minister of Finance, on 1 October 2018' (2018) < http://www.mas.gov.sg/News-and-Publications/Speeches-and-Monetary-Policy-Statements/Speeches/2018/Variable-Capital-
Companies-Bill-2018.aspx> accessed on 21 June 2019.
7 PricewaterhouseCoopers, 'Why not, indeed? A PwC viewpoint on creating a new platform for Singapore's asset management industry' (2013) < https://www.pwc.com/sg/en/publications/ampaper.html> accessed 24 June 2019.
8 Apart from fund management, the other 'regulated activities' under the SFA are (1) dealing in capital markets products; (2) advising on corporate finance; (3) real estate investment trust management; (4) product financing; (5) providing credit rating services; and (6) providing custodial services.
9 Monetary Authority of Singapore (n 4).
11 Asian Private Banker, 'The Role of Singapore as an Offshore Wealth Management Hub' (2018) < https://asianprivatebanker.com/industry/role-singapore-offshore-wealth-hub/> accessed 24 June 2019.
12 Asian Private Banker (n 9).
13 Reuters, 'Exclusive: Hong Kong tycoons start moving assets offshore as fears rise over new extradition law' (2019) < https://www.reuters.com/article/us-hongkong-extradition-capitalflight-ex/exclusive-hong-
kong-tycoons-start-moving-assets-offshore-as-fears-rise-over-new-extradition-law-idUSKCN1TF1DZ> accessed 24 June 2019.
14 Mercer, 'Quality of Living Worldwide City Rankings 2019 – Mercer Survey' (Mercer, 13 March 2019) < https://www.mercer.com/newsroom/2019-quality-of-living-survey.html#city-rankings> accessed 24 June 2019.
15 Inland Revenue Authority of Singapore, 'List of DTAs, Limited Treaties and EOI Arrangements' < https://www.iras.gov.sg/irashome/Quick-Links/International-Tax/List-of-DTAs--limited-treaties-and-EOI-arrangements/#B> accessed 21 June 2019.