VCC set-up by strategy: private equity, venture, hedge, real estate, private credit and tokenised funds compared

The same Singapore Variable Capital Company (VCC) can host a private equity, venture, hedge, real estate, private credit or tokenised fund, because a VCC may run open-ended or closed-end funds in traditional or alternative strategies (ACRA, January 2026). What changes by strategy is how capital comes in and goes out, which manager licence fits, how assets are valued and held, and which tax-scheme rules bite. This page compares the six strategies within one Singapore VCC; choosing between Singapore and other domiciles is a separate question for the network's domicile-comparison pages.

How to read this comparison

Each row mixes two kinds of statement. Rules come from MAS, ACRA or IRAS documents and are cited by name and date. Market practice describes how funds of that type are commonly structured; it is not a legal requirement, it varies between managers, and it carries no figures because there is no official source for fee levels, fund terms or timelines in the market. "Per fund documents" means the information memorandum, constitution and subscription agreement decide, not regulation.

The tax rows refer to MAS's 13O and 13U fund tax schemes, which apply only to funds holding an award, in basis periods in which all conditions are met. Designated investments (DI) are the asset classes whose income can qualify for exemption under those schemes; the list in Annex 3 of MAS FDD Cir 05/2026 applies from 1 August 2026. Nothing in the table is a recommendation of a strategy, structure or service provider.

The comparison table

Liquidity, licence and capital mechanics

Term structure and investor exit. The VCC's variable capital lets shares be issued and redeemed without shareholder approval (ACRA), which suits open-ended hedge funds dealing at NAV. Closed-end funds use the same feature differently: distributions can be paid out of capital as investments are realised. For venture funds using the VCFM regime this is a rule, not a choice: the fund "must not be continuously available for subscription, and must not be redeemable at the discretion of the investor" (MAS SFA 04-G05, Appendix 4, para 4.1(iii)).

Licence routes. A VCFM holds a capital markets services licence for fund management, may manage only venture capital funds meeting the 80/20 and unlisted-only tests, and may serve only accredited and institutional investors (MAS). How a VCFM maps onto the VCC Act's manager requirement should be confirmed with counsel. Other strategies use an LFMC.

Capital entry. Commitments, call notices and default remedies are contractual and set in the fund documents.

Valuation, custody and risk tools

For licensed fund management companies other than VCFMs, MAS expects independent custody and independent valuation; the valuation can be done by a third party such as an administrator or custodian, or by an in-house function segregated from investment management, and the annual audit on its own does not satisfy the requirement (SFA 04-G05, paras 4.1.1–4.1.2, last revised 3 September 2025). Independent custodians include suitably licensed prime brokers, depositories and banks.

MAS also sets minimum disclosures that matter most for liquid strategies: terms on gating, side-pocketing, lock-up or suspension of redemptions and any penalties; the definition and measurement of leverage; counterparties and prime brokers. Where a fund holds hard-to-value or illiquid assets, which is the normal case for real estate and private credit, the valuation methodology and procedures must be disclosed. For digital assets, MAS expects customers' assets to be segregated and the bulk stored in cold wallets. Detail is on valuation and NAV and hedge funds.

Tax-scheme rows: designated investments, committed capital and stamp duty

Designated investments. Under Annex 3 of MAS FDD Cir 05/2026, shares are DI except shares in an unlisted company trading or holding Singapore immovable property (developers aside); overseas immovable property is DI, as are real estate fund interests that do not invest in Singapore property. Loans are DI except loans to Singapore property-holding companies or loans financing Singapore property. Tokenised DI qualify where they confer the same rights as direct ownership (Annex 12, FAQ 9).

Committed capital. The fund types named in the table can meet the minimum fund size with legally enforceable commitments if part of the manager's fees is charged on committed capital and an annual declaration is made to MAS (Annex 7); venture funds are not named separately. Detail: private equity and venture.

Stamp duty. IRAS treats each sub-fund of an umbrella VCC as a separate person for stamp duty. An entity buying Singapore residential property pays ABSD of 65% for purchases on or after 27 April 2023 (IRAS, August 2026). See real estate and private credit.

Umbrella use and governing documents

Because one sub-fund's assets cannot be used to meet another's liabilities, a private equity manager can open a new sub-fund for each vintage, a hedge fund manager can separate strategies, and a tokenised share issue can be trialled in its own sub-fund. For the tax schemes, MAS treats an umbrella fund as one entity: local spending is counted across all sub-funds, and adding a sub-fund does not create a new award (FDD Cir 05/2026).

For tokenised funds, MAS's Guide on the Tokenisation of Capital Markets Products (last revised 14 November 2025) confirms that tokenised units in a collective investment scheme follow the same Part 13 rules, that offer exemptions carry advertising restrictions, and that holding customers' tokens may amount to providing custodial services. The Guardian Funds Framework (4 November 2024) is a set of industry best-practice recommendations, not regulation. See tokenised funds.

What this comparison does not cover: domicile choice (see vccfund.sg/compare in Chinese), the ACRA filing steps (vccfund.com.sg) and family-office structures (sgvcc.com). To interpret this for a specific fund, you can register your enquiry through the contact options on this site.