Introduction

On 18 April 2022, Monetary Authority of Singapore (“MAS”) unveiled new rulings which came into effect setting minimum requirements for capital or asset-under-management (“AUM”), local business expenditure, local investments and the hiring of investment professionals (“IP”) for the establishment of Single Family Offices (“SFO”) in Singapore. Many believe that the new tax exemption measures for new family offices in Singapore will likely attract more high net worth (“HNW”) families with significant AUM and have a positive impact on local investment and jobs.
Singapore recognized for its advantage as a regional hub for investors had attracted many prominent high net worth individuals from the West such as Ray Dalio, Sergey Brin and James Dyson to set up their family office in Singapore. The high barrier ensures that only the serious HNW families would consider setting up a SFO to create long-term substance in Singapore, and that HNW families uphold the agreement they make with MAS, to create employment and ensure Singapore companies invest locally, helping to strengthen Singapore’s economy further.
As Singapore continues to develop the ecosystem for SFOs certainly would attract those IPs who are EP holders to consider applying for Permanent Residency (“PR”) in Singapore.
The sole fast-track pathway to PR is the Global Investor Programme (“GIP”) administered by the Economic Development Board (“EDB”). Eligible and successful foreign investor applicants of the GIP are able to bypass the usual intermediate step of having worked in Singapore on an EP for some time before being eligible to apply for PR.
Here at Sim Mong Teck & Partners, we are well-versed with the GIP, its stringent requirements and finer intricacies, largely aided by our decades of experience with GIP applications.

Eligibility for Permanent Residency

Apart from the GIP, our firm also frequently handle applications for PR from the other pathways of eligibility. The other five (5) eligible categories from which applicants may apply for Singapore PR are:
– Spouse of a Singapore citizen (SC) or Singapore permanent resident (PR);
– Unmarried child aged below 21 born within the context of a legal marriage to, or have been legally adopted by, a SC or PR;
– Aged parent of a SC;
– Holder of an Employment Pass or S Pass (Professionals/Technical Personnel & Skilled Worker scheme); and
– Student studying in Singapore

Required Documentation

Firstly, the commonly required documents that the Immigration & Checkpoints Authority (“ICA”) will need are:
– Proof of employment: employment contracts, employer’s letters, evaluation reports, recommendation letters, employer contact information;
– Proof of education: diplomas and certificates from high school and above;
– Documents evidencing financial status: pay slips and other sources of income;
– Your recent resume/CV;
– Property ownership documents if you have real estate in Singapore;
– Personal information and biodata documents of yourself, your spouse and children (if any).

Procedure and Timeline

As of 2022, there are no longer walk-in appointments for PR applications at ICA, all PR applications must be submitted online using the e-Service. Applicants can either key in the application details online, or download and complete the PR application form offline before submission.
Please also note that all applications for PR are carefully considered and reviewed by ICA. Generally, PR applications take about six (6) months to process, provided all the required documents are submitted. Depending on the complexity of the case, some applications may take more than six (6) months to process.

The Unwritten Rules of Engagement

While the eligible pathways to PR are clearly stated by the ICA, the noteworthy use of the word “may” by the ICA belies the fact of the matter that ultimate discretion is retained by them, and they will also take into account factors such as an applicant’s family ties to Singaporeans, economic contributions, educational qualifications, age, family profile and length of residency, to holistically assess an applicant’s ability to contribute to Singapore and integrate into our society, as well as their commitment to establishing roots here.
In particular, an applicant’s economic contribution and social integration are key considerations which ICA will look at in the PR assessment process. With our experience, what we are able to do for our prospective clients is pinpoint potential areas of weakness to be worked on or conversely areas of strength to be highlighted in a potential applicant’s profile and future application. For example, in areas of social integration, through our network of contacts and working partners, we are able to offer support in linking interested clients up with a variety of charitable initiatives, volunteering opportunities and grassroots engagement that can bolster an applicant’s social integration profile.

Case Study

In relation to the abovementioned, we look back to one of our successful PR applications in 2020. We were approached by a certain Mr. A (hereinafter referred to as “our client”) as he seeks our assistance for his PR application.
Our client was an EP holder under his own personal company since 2015 drawing a monthly salary of more than S$10,000.00 and have been residing in Singapore for some time before he submitted his PR application on his own. He was subsequently rejected months later without any explanation or understanding why he was rejected by ICA.
Based on our analysis and experience, we managed to pinpoint the lacking elements in his previous application and began to devise a detailed roadmap to further his next PR application. Firstly, we assisted our client to set up his SFO under the 13X (currently known as 13U) Enhanced Tier Fund Tax Exemption Scheme and transferred his EP from his personal company to his SFO and concurrently hired his wife to be an investment professional of the SFO alongside our client to bolster their economic contributions for their PR application.
Secondly after setting up his SFO, we assisted our client to liaise with Community Foundation of Singapore (CFS) to understand more about setting up a foundation to better his social integration in Singapore. As our client’s objective is in line with CFS’s charitable objectives and goal to build a more caring and cohesive society in Singapore, he proceeded to set up his own foundation to contribute to Singapore’s educational and societal needs, particularly for the underprivileged families and vulnerable elderly.
Throughout the entire preparation process, we ensured that our client’s progress was in line with the roadmap we devised and we submitted his PR application upon achieving the milestones we set for him in the personalized roadmap created for him. In the preparation towards the submission of his PR application, we gathered all the necessary information, curated a tailored application cover letter drafted by one of our lawyers, highlighting the notable areas of contributions he may have made to Singapore as well as his unique circumstances and background and submitted his application along with our cover letter on July 2020. We are pleased to share that our client’s PR application together with his family of 3 were successfully approved in August 2021.

Conclusion

Ours is a bespoke, personal approach to navigating the unwritten rules of Singapore’s immigration law and policy, based on our clients’ differing needs and circumstances. With firm knowledge of the abovementioned pathways to PR, we stand ready to assist interested applicants who feel they may fall under one of these eligible pathways.