Singapore VCC vs Hong Kong OFC and LPF

Hong Kong offers two fund vehicles that sponsors weigh against the Singapore VCC. The open-ended fund company (OFC) is "an investment fund established in corporate form with limited liability and variable share capital" (SFC), which makes it the VCC's direct counterpart. The limited partnership fund (LPF) is a partnership with no legal personality, typically considered for closed-end private funds, and is closer to a Singapore limited partnership. This page compares the three on legal and regulatory features; it does not rank domiciles.

Two Hong Kong vehicles, two different jobs

For the OFC, the SFC is "responsible for the registration and regulation of OFCs", while the Registrar of Companies oversees incorporation and statutory corporate filings (Companies Registry). All OFCs, "whether publicly or privately offered, are required to be registered by the SFC"; a public OFC must also be authorised by the SFC under section 104 of the Securities and Futures Ordinance. Registration and authorisation are legal steps, not endorsements of a fund's merit — the same applies to ACRA registration of a VCC.

OFC vs VCC

The most visible structural difference is the mandatory custodian and two-director minimum for an OFC. For private OFCs, a licensed corporation or registered institution with Type 1 authorisation can act as custodian if it meets criteria in the OFC Code (SFC). ACRA's VCC pages set a lighter officer minimum; whether a particular VCC needs a custodian or more directors depends on the fund, its manager's MAS obligations and investor expectations, so check with Singapore counsel.

LPF vs VCC and the Singapore limited partnership

According to the Companies Registry, an LPF must have "one general partner who has unlimited liability" and at least one limited partner. Its investment manager must be a Hong Kong resident aged 18 or above, a Hong Kong company or a registered non-Hong Kong company. It must also appoint a responsible person — an authorised institution, licensed corporation, accounting professional or legal professional — to carry out anti-money-laundering measures under Schedule 2 of Cap. 615.

A VCC is a different animal: a company with shareholders, a board and a mandatory MAS-regulated fund manager, which must appoint an eligible financial institution to perform anti-money-laundering checks (MAS Notice VCC-N01). Sponsors wanting partnership economics in Singapore usually compare the LPF with the Singapore limited partnership, which became eligible for the section 13OA fund tax scheme from 1 January 2025 (MAS FDD Cir 05/2026). Sponsors wanting a corporate open-ended structure compare the VCC with the OFC.

Official fees and published timelines

Public OFCs pay higher SFC fees: HK$20,000 application and HK$10,000 authorisation for a single fund, HK$40,000 and HK$20,000 for an umbrella, and HK$5,000 and HK$2,500 per sub-fund (SFC, accessed 24 October 2026). The clocks above cover regulator or registry processing only; they exclude manager licensing, custodian appointment, bank accounts and investor documents. Fees are shown in their own currencies and not converted. The set-up time and cost page adds Cayman and Ireland.

Grants

The Government's grant scheme, administered by the SFC, subsidises eligible expenses paid to Hong Kong-based service providers for OFCs incorporated in, or re-domiciled to, Hong Kong. Under the Terms and Conditions dated 11 April 2025, the grant equals 70% of eligible expenses, capped at HK$300,000 per public OFC and HK$150,000 per private OFC, with a maximum of one OFC per investment manager; applications are accepted until 9 May 2027 and the period may be curtailed once the Government's funding is fully committed. Applications made before 11 April 2025 were assessed under the earlier, higher caps. The Government may claw back the grant if the OFC starts winding up within two years. Eligibility conditions apply and a grant is not guaranteed. Because the grant is tied to expenses paid to Hong Kong-based service providers, it interacts with the choice of legal adviser, administrator and auditor; a sponsor that would otherwise use providers elsewhere should compare like with like.

Singapore has offered grant support for VCCs in the past, but this site has not verified whether any VCC grant is open to new applications after January 2025, so no current Singapore grant is stated here; check with MAS directly. When comparing costs, treat any grant as a possible offset subject to approval, not as a reduction to plan around.

Tax at the fund level

Hong Kong's unified fund exemption came into operation on 1 April 2019. According to the Inland Revenue Department, "all funds, regardless of their structure, their central management and control location, their size or the purpose that they serve, will enjoy profits tax exemption subject to meeting certain conditions" (DIPN No. 61, June 2020). For context, PwC's Worldwide Tax Summaries (reviewed 22 July 2026) give Hong Kong's corporate profits tax rate as 16.5%, with 8.25% on the first HK$2 million under the two-tier system, and note a 0% concessionary rate for qualifying carried interest received on or after 1 April 2020, subject to conditions.

In Singapore, IRAS treats a VCC as a company for income tax and an umbrella VCC as a single entity. Funds may apply for the section 13O or 13U schemes, subject to conditions and approval; the schemes run to 31 December 2029 with a review promised beforehand (MAS).

Both regimes are conditional, and neither covers investors' or managers' personal tax. Applies to: Hong Kong and Singapore; mainland Chinese investors and managers need advice under mainland rules. General information, not tax advice.

Treaties, market data and moving in

The figures use different bases and should not be read as a ranking. Treaty access depends on the vehicle, the treaty partner's rules and the facts. Questions worth putting to advisers include: which investors' home jurisdictions matter, whether the manager is in Hong Kong or Singapore, and where the fund's central management and control will sit. The re-domiciliation regimes page compares the inward routes in detail. To discuss your situation, register your enquiry through the contact details on this site.