Tax for CMS licence holders/RFMC

Yes. Although a holder of a CMS license for fund management/RFMC is an Investment Entity, an FMC is a Non-Reporting Singaporean Financial Institution and shall be treated as a deemed-compliant foreign financial institution ("FFI"), as long as it fits the following definition:

• "An Investment Entity established in Singapore that is a Financial Institution solely because it
(1) renders investment advice to, and acts on behalf of, or
(2) manages portfolios for, and acts on behalf of, a customer for the purposes of investing, managing, or administering funds deposited in the name of the customer with a Financial Institution other than a Nonparticipating Financial Institution.” (para. VI.D of Annex II of the Schedule to the IT(ITCA)(USA)R)

To the extent that the assets of the FMC's customers that the FMC is managing are custodised / booked with a bank in Singapore in the name of the customer, the FMC qualifies for this exemption. For example, an EAM is simply managing the portfolios and acting on behalf of the customer for that purpose.

An FMC that manages the assets of a separate fund entity, e.g. a variable capital company ("VCC"), similarly acts on behalf of the fund entity. Also, banks in Singapore are not Nonparticipating Financial Institutions. As a Non-Reporting Singaporean Financial Institution the FMC is not a Reporting Singaporean Financial Institution (art. 1.1.(n) of the Schedule to the IT(ITCA)(USA)R) and the reporting obligation does thus not apply to the FMC (reg. 10 IT(ITCA)(USA)R).