Introduction
The Financial Investor Scheme (“FIS”) was a programme that allowed investors to acquire Singapore Permanent Residence (“SPR”) status by meeting specific investment criteria. Since its termination in 2012, FIS clients need to navigate a challenging landscape when renewing their Re-Entry Permit (“REP”)s. This article highlights the challenges faced by FIS clients as they seek to renew their SPR status and outlines factors that must be considered in the REP renewal process.

What is the FIS?
The FIS, introduced by the Monetary Authority of Singapore (“MAS”) in 2004, was designed to attract high-net-worth individuals (“HNWIs”) by offering SPR status in exchange for significant investments in Singapore. To qualify, applicants needed to demonstrate a net worth of at least S$20 million and invest a minimum of S$5 million with an approved financial institution. The scheme was revised over time, eventually requiring a S$10 million investment, part of which could be allocated to real estate. However, the FIS was subsequently terminated in 2012, following concerns that it was contributing to rising property prices and an overheated real estate market in Singapore.

Challenges in Renewing REPs for FIS Clients

The most significant challenge that FIS clients now face is that the Economic Development Board (“EDB”) will generally no longer assist FIS clients in their REP renewals. This entails significant uncertainty for FIS clients, as opposed to Global Investor Programme applicants who have clear REP renewal conditions outlined by EDB. This is exacerbated by the fact that the FIS has been discontinued for over a decade, and there is no explicit framework guiding the renewal of REPs for individuals who obtained their SPR through the FIS. REP renewals, which allow SPRs to maintain their status while traveling abroad, are not automatic and depend on several factors.

1. Lack of residency in Singapore

One of the most significant challenges for FIS clients is the requirement to demonstrate their rootedness to Singapore. Many FIS clients have spent extended periods outside Singapore, either for business or personal reasons. The Immigration & Checkpoints Authority (“ICA”) evaluates whether an individual has made Singapore their primary residence. Clients who have been away from Singapore for prolonged periods must provide compelling reasons for their absence and demonstrate an intention to return and contribute to Singapore.

1. Economic Contributions

Economic contributions are a key factor in REP renewals, and this poses a challenge for FIS clients who have not established substantial business or investment interests in Singapore. Unlike the GIP, where ongoing investments and economic contributions are tracked, FIS clients must provide evidence of their continued financial and/or economic commitment to Singapore. Without clear guidelines for REP renewals where the FIS is concerned, clients must prove their worth through their own platforms for contributing to the Singapore economy, such as setting up Singapore-based businesses or single-family offices (“SFOs”).

1. Increased Scrutiny and Changing Immigration Landscape

The ICA has become more stringent in evaluating REP renewals, particularly for individuals who have not been consistently residing in Singapore. FIS clients must provide a detailed REP renewal plan, outlining their economic and social contributions to Singapore. The changing immigration landscape, with tighter restrictions on foreigners, has made it harder for FIS clients to secure REP renewals.

Setting up Singapore – based SFOs and Businesses as a Solution

One strategy that has proven successful for some FIS clients is setting up SFOs in Singapore. SFOs contribute to the local economy through investments, job creation, and tax payments. Under MAS regulations, SFOs are required to invest a portion of their assets in Singapore-based investments, which helps to satisfy the economic contribution criteria required for REP renewal. FIS clients can also consider setting up businesses in Singapore, generating local employment and incurring local business expenditure.

Planning Ahead for REP Renewal

To avoid difficulties when applying for REP renewals, it is crucial for FIS clients to plan ahead. This includes establishing solid ties to Singapore through local investments and business ventures. Importantly, FIS clients should proactively demonstrate their intention to remain in Singapore for the long-term, even if they have spent considerable time outside Singapore.

Conclusion

For FIS clients, renewing a REP is far from straightforward. With the FIS no longer in operation and a lack of clear guidelines for renewals, clients face increased scrutiny and must demonstrate their ongoing commitment to Singapore. The path to a successful REP renewal requires careful planning, economic contributions, and a strategic approach, particularly for those who have not been residing in Singapore. At SMTP, we have successfully assisted FIS clients in navigating this challenging process by setting up SFOs and businesses in Singapore, ensuring they meet the requirements for REP renewal. If you or your clients are facing challenges with your PR renewal, our Business Development Team is available to assist with a tailored solution to suit your needs.