How is GST applied for an Umbrella VCC?
According to IRAS (e-Tax Guide – Tax Framework for Variable Capital Companies)
2.2 For GST purposes, each sub-fund of an umbrella VCC is regarded as a separate person, as a sub-fund makes independent sale and purchase decisions based on its respective investment mandate. Therefore, each sub fund is required to assess its GST registration liability based on the value of its taxable supplies made.
6.2 A non-umbrella VCC or a sub-fund of an umbrella VCC will be required to register for GST if the value of its taxable supplies or services acquired from overseas suppliers (“imported services”) exceeds $1 million for the past calendar year or is expected to exceed $1 million for the next 12 months.
However, you may be exempted or may apply for exemption from registration if the proportion of your zero-rated supplies over total taxable supplies exceeds 90% and you would be in a net refundable position had you been GST-registered.