Introduction
It is known that Singapore has offered routes to permanent residency for foreign investors since the 1970’s. The current incarnation of this is the Global Investor Programme (GIP). Whilst the current GIP’s pre-qualification bar and investment amount has been raised considerably in recent years, here at SMTP we still observe interest and the ongoing influx of enquiries on this fast-track scheme to Singapore permanent residency. What this article seeks to examine is the former FIS Scheme, its impacts and the current concerns of those successful applicants today in terms of renewing their PR Re-Entry Permits and attaining Singapore Citizenship.

Summary of the FIS
In 2004, Singapore introduced the Financial Investor Scheme, or FIS in short. The FIS allowed investments in investments in financial assets such as bank deposits, capital market products and collective investment schemes. At the time, investor applicants were required to have a net worth of around $20 million and invest S$5 million. The scheme was later modified to allow S$2 million of the S$5 million to be invested in selected real estate options. In 2010, the authorities then revised and doubled the minimum total investment to S$10 million.

From 2004 to 2012, a total of 1,080 investors were granted Singapore permanent residency status under the FIS.1 Investor applicants form Asia came primarily from China, Hong Kong, India, Japan, South Korea, Taiwan and ASEAN countries, while non-Asian investor applicants came from countries such as Australia, Canada, France, Germany, the United Kingdom and the United States. The Monetary Authority of Singapore (MAS) ended the FIS in 15 April 2012, amidst concerns at the time on the impact of the influx of wealthy immigrants on asset prices and the domestic property market.
Whilst the FIS was administered by the MAS, its successor, the Global Investor Programme (GIP) is administered by a division within the Economic Development Board (EDB) known as Contact Singapore, accords Singapore Permanent Resident status (PR) to eligible foreign global investor applicants, their spouse and children under the age of 21 who intend to drive their businesses and investment growth out of Singapore as a base of operations.

Applicants will need to have a substantial business track record and successful entrepreneurial back-ground to qualify. Our past newsletters have examined the four different pre-qualifying categories through which interested applicants can apply for the GIP under if they meet the criteria.

The FIS Dilemma and how SMTP can assist
In recent times, we have observed that the renewal processing times for REP applications are increasingly becoming longer, and the ICA’s overall position towards assessing renewals becoming stricter. For applicants who had obtained PR through FIS, or via the GIP, and need help with renewals of their REP or applying for Citizenship, it has been our experience that Contact Singapore will be able to assist and support their applications provided that the applicants are able to establish and substantiate their economic contributions to Singapore. We are able to assist our clients in reaching out to Contact Singapore for assistance in the renewals of the REP/REP renewal appeals, for the main investor PR or his/her dependent. PR’s who obtained their status through the Professionals, Technical Workers and Skilled Workers route as well as 2nd generation PR children of FIS applicants will not be eligible for such assistance from Contact Singapore.

The common REP renewal issues for former FIS applicants that we observe are that of adequate residency in Singapore and economic contributions. Some face an obvious lack of residency and stay in Singapore over the course of their 5-year PR terms, while others may reside in Singapore but for less than half of the 5 year period and also have a clear lack of economic contributions.

At SMTP, we can assist our clients in assessing their residency and economic contributions to-date in the lead up to their upcoming REP expiries, as well to touch base with Contact Singapore to seek their guidance, inputs and support for our clients’ renewal applications. A useful and contemporary tool in support of their REP renewal for FIS PR’s to consider are the Section 13R or Section 13X Single-Family Office tax exemption incentive schemes, which are administered by MAS. These are recognized and welcomed programs by Contact Singapore for PR’s to consider establishing to bolster their economic contribution profile, and they also offer the considerable benefit of according full tax exemptions in Singapore on specified income from designated investments.

Similarly, Contact Singapore can provide assistance for those interested in applying for Singapore Citizenship (SC), if the applicant is the main FIS investor PR or his/her dependent. Here at SMTP, we are well-versed in assisting and advising clients on the required process of applying for Singapore Citizenship, what are the key economic metrics Contact Singapore are looking out for in order to render their support for a Citizenship application, and the other unwritten rules of engagement in tackling an application for Singapore Citizenship, particularly for former investor PR’s who may not have the ideal length of residency and holistic integration into mainstream Singapore-an society.

Conclusion
At SMTP, as a specialized private client law firm, we offer a bespoke, personal and service-oriented approach to each individual client, and we stand ready to assist FIS applicants who may be facing issues with their REP renewals or who may have long-term goals of conversion to Singapore Citizenship. For the avoidance of doubt, the information above does not constitute legal advice of any sort. The information provided in the presentation slides are current as at the date of publication but can be subjected to change without notice. Should you or your clients be interested or require any assistance, please feel free to contact our Business Development Team to schedule a consultation with us.