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Public Consultations

Public Consultation on Proposed Legislative Amendments for the GST and Stamp Duty Treatment of Variable Capital Companies (VCCs)

14 Feb 2019


  1. The Ministry of Finance is seeking public feedback on the proposed amendments to the Goods and Services Tax Act (“GSTA”) and Stamp Duties Act (“SDA”), which will be incorporated into a Variable Capital Companies (Miscellaneous Amendments) Bill 2019. The consultation period is from 14 February to 1 March 2019.

  2. We invite you to comment on the drafting of legislative amendments which will give effect to the proposed tax policy changes. Your views on the drafting will help us improve the clarity of the legislative amendments.


  1. The Variable Capital Companies Act 2018 (“VCC Act”) was passed by Parliament on 1 October 2018. The VCC Act provides for the incorporation and operation of a new corporate structure for investment funds, and is expected to come into operation in the second half of 2019. The VCC structure will complement and expand the existing suite of fund structures in Singapore. The introduction of VCCs strengthens Singapore’s position as a full-service international fund management centre, and provides opportunities to fund managers and fund servicing professionals such as fund administrators, lawyers, and accountants.

  2. As conveyed during the second reading of the Variable Capital Companies Bill in Parliament on 1 October 2018, the tax framework for VCCs is to be separately set out via legislative amendments to the relevant tax legislation.


  1. The proposed tax treatment for VCCs, which is formulated in consultation with the industry, recognises the unique characteristics of VCCs, which combine the advantage of a single legal entity at the VCC level with segregation of assets and liabilities at the sub-fund level. The legislative amendments to the relevant tax legislation are expected to come into operation in the second half of 2019. Salient aspects of the proposed tax legislative amendments for consultation are as follows:

    1. Goods and Services Tax (“GST”). GST will be applied at the sub-fund level (i.e. if liable, each sub-fund is required to separately register, charge, account for and file GST returns). This is because each sub-fund makes independent sale and purchase decisions based on its respective investment mandate

    2. Stamp Duty (“SD”). SD treatment will be applied at the sub-fund level in view of the segregation of assets and liabilities of sub-funds within an umbrella VCC.

    The public consultation on the proposed amendments to the Income Tax Act (“ITA”) will be separately conducted in due course.

  2. The summary table provides a brief description of the tax changes and explains the amendments to the GSTA and SDA in detail.


  1. We appreciate your support and participation to ensure that the consultation is productive and focused. Respondents are requested to observe these guidelines:

    1. Kindly identify yourself and the organisation you represent (if any) so that we may follow up with you to clarify your comments if needed.

    2. Be clear and concise in your comments.

    3. Focus your comments on how the legislative amendments can be better written to make them clearer and to make compliance easier.

    4. Use the prescribed template provided to organise your feedback.

    5. As far as possible, please explain your points with illustrations, examples, data or alternative formulations of the amendments.

  2. These draft legislative amendments are released only for the purpose of consultation and should therefore not be used for individual or business decisions as it does not represent the final legislation. All comments received during the consultation will be thoroughly reviewed and if accepted, will be incorporated into a Variable Capital Companies (Miscellaneous Amendments) Bill 2019 for introduction in Parliament.


  1. The public consultation is from 14 February to 1 March 2019; all comments received after 1 March 2019 will not be considered.


  1. We encourage all interested parties to submit your comments, using the prescribed template, through:

    1. email to for GST related feedback and for SD related feedback (preferred mode); or

    2. fax to 6337 4134; or

    3. post to:

      Ministry of Finance
      100 High Street, #10-01
      The Treasury
      Singapore 179434
      Attention: Tax Policy Directorate


  1. We will publish a summary of the main comments received on the Ministry of Finance’s website, together with our responses, by May 2019. The identity of respondents will not be disclosed in the summary.


  1. For reference, please click here to download the relevant documents for this public consultation.