On this Page:
- Singapore: The
Tax System and Wealth
- Singapore: Inheritance Taxes
- Singapore: Banks, Stocks and
Real Estate
- Singapore: Alternative Investment
- Singapore: The Wealth Management
Industry
Singapore:
The Tax System and Wealth
All
individuals pay tax on income earned or received
in Singapore; however overseas income received
in Singapore after January 1, 2004, including
income paid into a Singapore bank account (but
excluding overseas income received through a
partnership in Singapore), is not taxable.
Income
tax is assessed based on a preceding year basis.
Tax
Rates in 2010
Individual
-
The
income tax rates for resident individuals
are as follows:
Chargeable
income
|
Rate
(%)
|
Gross
tax payable (SGD) |
First
SGD20,000
Next SGD10,000 |
0
3.5 |
0
350 |
First
SGD30,000
Next SGD10,000 |
–5.5 |
350
550 |
First
SGD40,000
Next SGD40,000 |
–8.5 |
900
3,400 |
First
SGD80,000
Next SGD80,000 |
–14 |
4,300
11,200 |
First
SGD160,000
Next SGD160,000 |
–17 |
15,500
27,200 |
First
SGD320,000
Next SGD320,000 |
–20 |
42,700 |
There
is a one-off personal income tax rebate
of 20% for resident individuals, subject
to a cap of SGD2,000, for tax payable
for year of assessment 2009.
The
income tax rate for non-residents’
employment income is either 15% or the
relevant resident tax rate, whichever
produces the highest sum. Director's fees,
consultation fees and most other income
are taxed at 20%, which is generally withheld
at source.
Certain
other payments to non-resident individuals
are subject to withholding tax at source.
The
majority of dividend payments received
are exempt from income tax.
Corporate
- The
normal rate of Profits Tax is 17%.
Capital
gains
-
Generally,
capital gains realised from the sale of
property in Singapore, or derived from
buying and selling shares or other financial
instruments, are not subject to tax.
If,
however, such sale of property or buying
and selling of shares and other financial
instruments are regarded as a trade, the
gain may be regarded as taxable income.
Indirect
Taxes
-
Companies
must register for goods and services tax
(GST) if their turnover for the previous
12 months exceeds SGD1m, or if the business
reasonably expects its turnover will exceed
SGD1m over the following 12 months. Voluntary
registration is permitted, for example
where the company intends to make taxable
supplies, only supplies goods outside
Singapore, or makes exempt supplies of
financial services that are also deemed
to be international services. A foreign
company registering for GST must appoint
a Singapore agent to act on its behalf
on all its GST matters, including the
accounting and payment of GST.
The
standard rate of GST is 7%, and applies
to most sales of goods and services made
in Singapore. Exports and related international
services are zero-rated. Financial services
and the sale or lease of residential properties
are exempt from GST.
Real
Estate Taxes
- Property
tax is charged on immovable property, including a
house, building and land. The amount of tax due is
calculated based on a percentage (tax rate) of the
annual value of a property. The tax rate is 10%, or
4% where the property is granted an owner-occupier
concession.
From
January 1, 2011, the 4% tax rate will be replaced
by a three-tier tax rate based on the annual value,
as follows:
Annual
value
|
Tax
rate |
First
SGD6,000 |
0% |
Next
SGD59,000 |
4% |
Above
SGD65,000 |
6% |
Other
Taxes.
-
Stamp
duty is payable on certain executed documents
relating to properties and shares, or interest
in properties and shares. Such documents include
a lease, sale, purchase, gift or mortgage of property.
Liability arises once the document is executed,
even if the transaction itself has been aborted.
The
amount of duty payable varies according to the
transaction. For example, in the case of a mortgage,
the duty is SGD4 for every SGD1,000 or part thereof,
subject to a maximum duty payable of SGD500..
Withholding
Taxes
- There
are no domestic withholding taxes on dividends,
interest or royalties.
Evidently
this is a tax regime which is conducive to the accumulation
of wealth. The number of rich people and their wealth
is reportedly growing at more than 30% annually in Singapore,
double the global average.
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Singapore: Inheritance Taxes
There
is no estate duty in Singapore.
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Singapore:
Banks, Stocks and Real Estate
Singapore
is one of the world’s fastest growing private
banking centres, as demonstrated by the many global
banks that have set up offices there. The jurisdiction
has strict banking secrecy laws, yet it aims for
a transparent economy and complies with the requirements
of the OECD “white list”. All banks
operating in Singapore must be licensed by the Monetary
Authority of Singapore, which is the jurisdiction’s
central bank.
On
December 1, 1999, the Stock Exchange of Singapore
and the Singapore International Monetary Exchange
merged to form the Singapore Stock Exchange (SGX).
On November 23, 2000, it was the first Asia-Pacific
exchange to be listed via a public offer and a private
placement. The SGX’s stated aim is “to
offer a highly trusted securities & derivatives
marketplace for capital raising, risk transfer,
trading, clearing and settlement”.
The
SGX has forged a number of strategic alliances with
other exchanges, including: a joint venture with
the American Stock Exchange to promote Exchange
Traded Funds; a securities co-trading link with
the Australian Stock Exchange; an agreement with
the Baltic Exchange for the provision of the Baltic
Exchange’s benchmark prices for the settlement
of Forward Freight Agreements; and a futures trading
link with the Chicago Mercantile Exchange.
In October, 2010, the Australian stock exchange,
ASX Limited (ASX), and the Singapore Exchange (SGX)
announced that they had entered into an AUD8.4bn
(USD8.35bn) merger implementation agreement.
In
a joint statement, the two exchanges have said that
their combination “will bring together the
complementary businesses of two successful exchanges
in the Asian time zone, with internationally recognised
regulatory standards. The combination leverages
the strengths of ASX through its listings, stock
options and fixed income franchises, with SGX, the
Asian gateway for international listings, equity
futures and OTC clearing, to create the region’s
pre-eminent exchange group.”
“The
combined group,” they added, “will augment
Australia’s financial market and funds management
industry through direct participation in Asian growth,
and increase ASX’s and SGX’s competitiveness
in a changing global markets landscape. As proven
platforms for raising capital and managing price
risk for the resource sector, ASX and SGX will build
on existing distribution and clearing capabilities,
and intend to play an important role in establishing
price discovery for global commodities in the Asia-Pacific.”
The
combined group, with ASX-SGX Limited as its holding
company, will have pro forma revenues of approximately
USD1.1bn and pro forma earnings before interest
and income tax of approximately USD700m, based on
the audited financial statements of ASX and SGX
for the financial year ended June 30, 2010.
It
would, however, only be the second largest exchange
in Asian. The Hong Kong Stock Exchange is expected
to remain as Asia’s primary exchange, and
is likely to remain so given its links to mainland
China and its development of yuan-denominated business.
Nevertheless,
ASX and SGX will still, it is said, offer access
to over 2,700 listed companies from over 20 countries;
to the world’s second largest cluster of companies
in the resource sector (more than 900 listings);
and to the largest real estate investment trust
sector (over 80) and the largest number of exchange
traded funds (over 100) in the Asia-Pacific.
It
will also offer the world’s widest range of
Asia-Pacific equity, fixed income and commodity
derivatives with over 400 contracts from over 10
countries, including Australia, China, India and
Japan, and covering a range of commodities including
metals, energy and agricultural products.
In
addition, it will have the Asia-Pacific’s
largest and the world’s second largest base
of institutional investors with combined assets
under management of over USD2.3 trillion from existing
superannuation, institutional and sovereign wealth
funds.
With
a global distribution network with over 90 securities
market participant firms and over 170 derivatives
market participant firms on a combined basis, it
will possess leading exchange technology, including
the proposed introduction of the world’s fastest
trading platform.
Structured
as a takeover of ASX by SGX, it is expected that
the combined group’s chief executive officer
and non-executive chairman will come from the latter,
while ASX will only provide its deputy chairman.
It is also reported that 40% of the holding company’s
shareholders will be Singaporean, with 30% Australian
and the remainder international investors.
In
his 2006 budget, Lee Hsien Loong announced a range
of tax and other initiatives aimed at spurring growth
in the financial services and asset management industry.
Among the measures designed to promote the development
of Singapore as a financial centre were enhanced
tax incentives for asset and wealth management,
capital and treasury markets, and captive insurance.
With
a view to encouraging the growth of financial services
companies the Government grants the following categories
of fiscal incentives:
- Trading
Income: Capital gains and income made by financial
service companies trading investments for and
on behalf of their non-resident clients are
often tax exempt both in the hands of the financial
services company and in the hands of the non-resident
client. The effect of this incentive is to make
Singapore an attractive location for foreigners
to base their investments.
-
Fee Income: Concessionary tax rates are levied
on profits earned by financial services companies
in respect of income earned billing clients
for investment services rendered. Profits distributed
as dividends are also granted a concessionary
tax status.
Bond
Market
Debt market tax concessions have traditionally included:
- A
concessionary tax rate of 10% on interest income
from holding qualifying debt securities arranged
in Singapore.
-
Withholding tax exemption on interest from qualifying
debt securities arranged in Singapore payable
to non-residents.
-
Withholding tax exemption on swaps in relation
to SGD bond issues. Issuers are automatically
waived from the requirement under S45 of the
Income Tax Act to withhold tax on interest paid
on qualifying debt securities.
Foreign
Securities Companies
Companies
which deal in foreign securities have traditionally
been entitled to various fiscal concessions. The
rate of corporate income tax payable depends on
the nature of the activity. For example:
-
A
corporate income tax rate of 10% is payable
on income earned from providing advice to and
buying and selling foreign securities on behalf
of non-residents.
-
Income
earned from arranging and underwriting initial
public offerings of foreign currency denominated
shares on the Singapore stock exchange and from
transactions in respect of the same are exempt
from corporate income tax.
-
Dividends:
In Singapore there are no withholding taxes
levied on dividends. Instead dividends are taxed
at the standard rate, with a tax credit being
given for any corporate tax levied on the profits
out of which dividends are paid. Where there
is a shortfall between the tax credit and the
charge levied on dividends the shortfall must
be made up by the company paying the dividend
and not by the shareholder receiving it. Companies
which deal in foreign securities on behalf of
non-residents are exempt from any further taxation
on the shortfall in so far as that shortfall
is caused by the concessionary fiscal status
granted to the company.
-
Commodity
derivatives: Under this scheme, a concessionary
tax rate of 5% will be granted for income derived
from qualifying activities undertaken by a financial
institution granted Commodity Derivatives Traders
(CDT) status.
Financial
Services Processing Companies
To
promote Singapore as the hub for high value-added
processing activities, a tax incentive scheme for
Qualifying Processing Services Company ("QPC")
was introduced in 2004.
This
scheme aimed at encouraging companies which undertake
high value-added processing services supporting
financial institutions to set up their operations
in Singapore. Under this scheme, a QPC would be
granted concessionary tax rate of 5% on income derived
from the provision of the prescribed processing
services, which are in support of financial activities
such as Treasury and Securities, Asset Management,
Private Banking, Wholesale Banking and Retail Banking.
Examples
of core processing services which are eligible under
the scheme are settlement and reconciliation, cash
management, product control, securities borrowing/lending
processing, portfolio valuation, etc. In addition,
ancillary services such as risk management, IT processing,
financial control, compliance and legal, and management
information and reporting, which are in support
of the core processing services, may also be eligible
under the incentive.
Credit
Rating Agencies
With
a view to encouraging the growth of companies which
provide credit rating services on foreign securities
such companies have traditionally been entitled
to the following fiscal concessions:
-
Profits
are subject to an indefinite 10% concessionary
tax rate.
-
Dividends: In Singapore there are no withholding
taxes levied on dividends. Instead dividends
are taxed at the standard rate, with a tax credit
being given for any corporate tax levied on
the profits out of which dividends are paid.
Where there is a shortfall between the tax credit
and the charge levied on dividends the shortfall
must be made up by the company paying the dividend
and not by the shareholder receiving it. Companies
which deal in foreign securities on behalf of
non-residents are exempt from any further taxation
on the shortfall in so far as that shortfall
is caused by the concessionary fiscal status
granted to the company.
R&D
Expenses (Financial Products Research)
This
incentive, which was designed to encourage financial
institutions in Singapore to develop new and innovative
financial products, has traditionally allowed double
tax deduction for expenses such as the cost of R&
D personnel, legal expenses, training costs and
consultancy fees. The Innovation in Financial Technology
& Infrastructure Grant (ITIG) Scheme, introduced
in 2004 (now named the Further Deduction for R&D
Expenses Scheme), was launched to encourage innovation
in technology and/or infrastructure in financial
services. The scheme was designed to target Singapore-registered
companies, and offer grants for qualifying expenses
with respect to innovation in financial technology
and/or infrastructure activity in Singapore.
Approved
Trustee & Custodian Companies
The
Tax Incentive Scheme for Approved Trustee Companies
has traditionally been aimed at encouraging the
development of reputable trustee companies and banks
to offer international trust administration and
custodian services in Singapore, as well as to complement
the growth of the fund management industry in Singapore.
Under the scheme, an Approved Trustee Companies
(ATC) would be granted a 10% concessionary rate
on income derived from the following:
- Trustee
or custodian services in respect of a foreign
trust created in writing, i.e. where both the
settlor and beneficiaries of the trust are not
residents or citizens of Singapore (and, if
a company, not incorporated in Singapore or
controlled by persons who are residents or citizens
of Singapore);
- Trustee
or custodian services for or on behalf of a
unit trust which is not owned or controlled
by Singapore residents or citizens, and whose
funds are invested in "designated investments";
- Trustee
or custodian services in respect of foreign
bond or loan stock issues (e.g., monitoring
loan covenants, administering loan repayments);
- Custodian
services for foreign currency denominated stocks
and shares issued by companies not incorporated
and not resident in Singapore; and
- Provision
of trust management or administration services
to foreign trusts of which it is not the trustee,
including the setting up and administration
of eligible investment holding companies for
such trusts.
Offshore
Insurance Business
To
encourage insurance companies, in particular professional
reinsurers and captives to set up operations in
Singapore to write offshore business, a concessionary
tax rate of 10 per cent has traditionally been granted
to insurance companies on income derived from:
-
Underwriting profits of offshore insurance business;
and
-
Non-Singapore sourced dividends, realised capital
gains and interest including interest on Asian
Currency Unit (ACU) deposits, derived from investing
offshore premium income and shareholders' funds
used to support the offshore insurance business.
The
Tax Exemption Scheme for Marine Hull & Liability
Insurance Business aims to encourage all general
direct insurance and reinsurance companies (including
P&I clubs) in Singapore to tap the insurance
potential of the shipping communities in the Asia
Pacific region. It provides tax exemptions for income
derived from underwriting profits of marine hull
and liability business, as well as non-Singapore
dividends, realised capital gains and interest,
including Asian Currency Unit (ACU) deposits, derived
from investing premium income from offshore marine
hull & liability insurance business and shareholders'
funds used to support the marine hull & liability
insurance business.
Singapore's
2006 budget gave tax exemption to captive insurance
companies for a period of 10 years on specified
types of income; the exemption will be available
until 2011.
Real
Estate
With
more than USD3bn of commercial property sales in
Q3 2010, Singapore ranked third in the Asia Pacific
region after Japan and Australia. Q1 had seen a
comparable level of activity, although Q2 was lower.
Altogether,
it's clear that the Singapore commercial property
market is back to full health after problems in
2008 and 2009. A new business development, the Marina
Bay Financial Centre, has helped to boost Singapore's
image as a regional business centre.
There is considerable over-supply of commercial
space at present, after completions in 2008 and
2009 failed to find immediate tenants, particularly
in the retail sector, where a number of new malls
came on the market in 2009.
A
study issued by consultancy DTZ in August, 2010,
says that Singapore's commercial properties offer
highly attractive returns, and the firm expects
that rents will show strong growth in the next five
years.
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Singapore:
Alternative Investment
In
September, 2010, Singapore was tipped in a PricewaterhouseCoopers
(PwC) report to beat Hong Kong in the asset management
sector.
PwC
expects “to see a general shift of the world’s
largest clusters from developed to emerging and
developing nations as the centre of global economic
gravity continues to shift towards these countries.”
It
forecasts that “the existing large clusters
in New York, London and Boston will be joined
by Singapore, which may become the leading cluster
in the Asian region. Tighter regulation and higher
taxes are currently working against clusters in
the United States and Europe but the key factor
will be the increase in public and private capital
available in Asia – which will fuel growth
in asset management in the region.”
In
its analysis, it expects the existing asset management
clusters of Hong Kong and Singapore to both grow
rapidly. It says that “both locations offer
less burdensome tax regimes than their western
counterparts and have ‘well-regulated but
moderate’ regulatory structures.”
However,
in its view, “there can only be one dominant
regional centre in Asia. This is because of the
enormous benefits accruing from knowledge spillovers
and labour force specialisation in this industry.
At present, we see the competition to be the regional
asset management centre between Hong Kong and
Singapore.”
“In
the first half of 2010,” it says, “Hong
Kong out-performed Singapore in attracting start
up asset management funds with 65% of Asian fund
launches during the period occurring in Hong Kong.
However, with the Singaporean government actively
promoting the city as a global centre for asset
management and with a higher existing value of
assets under management, Singapore is well-placed
to compete with Hong Kong going forward.”
It
concludes that “while Hong Kong’s
proximity to China allows it access to the growing
Chinese market, it will also be competing with
other financial centres within China, such as
Beijing, for a majority share of the Chinese asset
management market. As a more independent cluster
in close proximity to Indonesia, Malaysia and
Thailand, we expect Singapore to attract the internationally
footloose capital and become the second largest
global asset management cluster by 2025.”
Therefore,
by 2040, “the three largest clusters by
value of assets under management are projected
to be New York, Singapore and London. Despite
growth in Asian markets, New York is projected
to retain its position as the dominant asset management
cluster.”
Hedge
Funds
Singapore
is emerging as the most popular Asian location amongst
hedge fund managers for fund start ups, and in June
2006, Singapore Exchange Ltd (SGX) announced that
it would accept listings of hedge funds from the
end of that month.
Although
eligible hedge funds were listed, however, there
was to be no trading in their units on SGX. Typically,
issue and redemption takes place in the over-the-counter
market.
The
new listing rules for hedge funds had the following
key features:
A
hedge fund must:
- Be
authorised or recognised under section 286 or
287 of the Securities and Futures Act; or be
offered only to institutions and/or accredited
investors.
- Have
a minimum asset size of at least SGD20 million
(at the time the new rules were introduced)
or USD20 million for Singapore and foreign currency
denominated funds respectively.
Under
additional rules:
Fund
managers are required to have in place an independent
risk management function.
The
investment management team of a hedge fund is expected
to have at least one principal with a minimum of
five years relevant investment management experience.
A
hedge fund will announce its net asset value per
unit, as soon as practicable after each month end,
but in any event no later than seven business days.
In
addition, a fund must immediately announce any material
change relating to its operations, including but
not limited to, any change in its investment manager,
custodian, administrator or independent auditor.
The factor that has appeared to spur hedge fund
growth in Singapore is the relatively short time
taken to register a fund in the city-state, an issue
identified by hedge fund managers as the most crucial.
Fund
Management
Fund
management companies have traditionally been entitled
to the following fiscal concessions:
- Fee
income received by fund management companies
in respect of services rendered are exempt from
corporate income tax for a period of 5 years
provided the fund management company manages
an asset portfolio with a value in excess of
SGD5m (at the time of writing). The exemption
period can be 10 years if the fund managers
can make suitably strong commitments to significantly
increase their level of fund management activities
in Singapore. The exemption is granted by the
monetary authority of Singapore on a case by
case basis.
-
Dividends: In Singapore there are no withholding
taxes levied on dividends. Instead dividends
are taxed at the standard rate, with a tax credit
being given for any corporate tax levied on
the profits out of which dividends are paid.
Where there is a shortfall between the tax credit
and the standard rate charge levied on dividends
the shortfall must be made up by the company
paying the dividend and not by the shareholder
receiving it. Companies engaged in fund management
are exempt from any further taxation on the
shortfall in so far as that shortfall is caused
by the concessionary fiscal status granted to
the company.
Regulatory
changes introduced in 2004 meant that international
fund managers are no longer required to maintain
a physical presence in the territory, and are permitted
to make their funds available via private banks.
The
number of hedge funds in Singapore grew from just
eight in 2001 to more than 50 in 2004. However,
accounting firm PricewaterhouseCoopers warned that
future growth in the industry would be stifled unless
the government made key changes to tax legislation.
The
firm called on the government to address the rule
requiring at least 80% of investments in foreign
hedge funds to have originated from overseas in
order for them to qualify for tax exemption.
"They
probably have to relook at the 80-20 rule,” observed
Deepak Kaul, Manager, Corporate Tax Services, PwC.
He added: “I think the easiest thing is to do is
to relax the imposition of the 80-20 rule, maybe
make it applicable over a period of time. In which
case then, even fund managers who are not meeting
the 80-20 rule initially will be incentivised to
actually start up in Singapore."
Singapore's
Prime Minister Lee Hsien Loong responded by announcing
in his 2005 budget that start-up fund managers would
be given a 12-month grace period to meet the requirement
that 80% of share capital must come from foreign
investors to qualify for a 10% tax rate on fee income.
The
80-20 rule was rescinded by the Monetary Authority
of Singapore (MAS) in August 2007, and the requirements
for benefiting from the aforementioned tax exemption
were significantly loosened.
The
other aspect of hedge fund taxation that industry
participants called for to be changed was the level
of the 10% tax, considered somewhat high by many.
By cutting this levy to 5%, observers believed that
Singapore would be able to continue to carve out
a niche as a centre for the management of Indian,
Japanese and Korean-based funds, in addition to
capturing some of the growing interest in specialist
Islamic hedge funds.
In
his 2005 budget speech, Lee Hsien Loong announced
that foreign non-individual investors would be encouraged
to invest in the Singapore property market with
a proposed reduction in the withholding tax on REIT
distributions to 10% from 20%, for a period of five
years. Additionally, to attract more REIT listings,
the government wants to waive stamp duty on the
instruments of transfer of Singapore properties
into REITs to be listed, or already listed on the
SGX, for a five-year period.
In
his Budget Speech for the Financial Year 2009, which
was delivered in Parliament on Thursday, January
22, 2009, Minister for Finance, Tharman Shanmugaratnam
announced that the tax exemption schemes for foreign
investors and qualifying resident funds, and tax
incentive schemes for approved trustee companies
and financial sector incentive companies would be
enhanced by expanding the list of specified income
and designated investment.
In May, 2010, the Monetary Authority of Singapore
(MAS) – the jurisdiction’s central bank
– said in a statement that it is to review
its rules for the fund management industry. The
review will include hedge funds, fund managers,
and investment managers.
The
review will include a re-examination of how investment
and alternative fund managers interact with their
investors and stakeholders. The MAS emphasized,
however, that it remains committed to efforts to
develop Singapore as a key alternative investment
and fund management hub.
The
MAS believes the review “is essential for
the long-term and sustainable growth” of the
industry.
The
city state’s hedge fund industry is the second
largest in Asia. Growth in the sector has been promoted
through tax breaks and incentives offered to foreign
companies setting up business there, as well as
light or, in some cases, no regulation – particularly
for hedge funds with 30 or fewer professional investors
that qualify under MAS guidelines. Those regulations
that are in place for such hedge funds relate to
money-laundering and local rules relating to securities
and futures trading, which require hedge funds to
be sure of their clients’ financial awareness.
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Singapore:
The Wealth Management Industry
Singapore
is reputed to have the highest density of millionaires
in the world, and along with Hong Kong, which might
want to dispute that assertion, is riding high in
the global wealth management stakes, as the wealthy,
or at least their assets, decamp from traditional
havens in Europe and the Americas.
A
comparison with Switzerland is particularly apt,
as that country comes under unremitting pressure
from the EU and the USA to weaken traditional banking
secrecy. No such pressure is being exerted on Singapore,
although the city-state has agreed to incorporate
the OECD's standard wording for exchange of information
in a number of its tax treaties and TIEAs. Assets
under management in Singapore are thought to total
about USD1 trillion, as against USD3 trillion in
Switzerland, but the gap is closing fast. The central
bank says that about half of these assets come from
outside the Asia-Pacific region.
Of
course, Singapore, like Hong Kong, will have no
truck with the EU's Savings Tax Directive.
The
result of the flood of money coming Singapore's
way in recent years has been a doubling in the number
of major banks offering wealth management services
in the city-state to more than 40.
For
the third time, the world's leading Shorex wealth
management forum is moving to Singapore to address
the growing need of the Asian market for private
banking, asset management and international tax
planning solutions and services. The event is an
exhibition and conference offering a unique platform
where professionals can network to explore new services,
products and ideas in wealth management.
The
Shorex Wealth Management Forum in Singapore in 2011
is expected to attract over 50 exhibitors and 1400
delegates.
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