2025 was a decent month for Singapore fundraising. Supabase brought in $240 million, Thunes another $190 million, Bolttech $185 million. What was less visible from the press releases is where the companies’ parents actually sat. In every case, the structures involved at least two jurisdictions outside Singapore, and sometimes four.
The triangulation is not new. What has changed is how much it now costs to get wrong.
Southeast Asian tech raised $5.2 billion across 2025, down sharply from prior years, per DealStreetAsia’s full-year tally. Scarce capital made investors pickier. Venture counsel in Singapore and Hong Kong report that term sheets from tier-one funds now carry representations on economic substance compliance and beneficial ownership filings. Those clauses rarely appeared in Asian venture documentation half a decade ago. Where a company’s parent sits is no longer a footnote in the closing binder.
Four jurisdictions keep showing up: Singapore, the British Virgin Islands, the Cayman Islands, and Hong Kong. Each has moved in the last three years, though in different directions and for different reasons.
Singapore
The headline corporate tax rate is a flat 17 percent. Newly incorporated startups generally pay far less, often between 4 and 9 percent effective, because the Start-Up Tax Exemption removes 75 percent of the first S$100,000 of chargeable income and 50 percent of the next S$100,000, for three years of assessment. Budget 2026 added a 40 percent corporate tax rebate capped at S$30,000 and a S$1,500 cash grant for companies keeping at least one local employee.
The tax numbers are the least interesting thing about Singapore.
Capital gains go untaxed. Dividends reach shareholders through a one-tier system with no further layer. The city-state has more than 90 double tax treaties, and its registry, ACRA, runs almost entirely online. Institutional investors in the US and Europe can underwrite Singapore entities without flying anyone in. StartupBlink’s 2025 Global Startup Ecosystem Index put the city fourth worldwide with 3,856 tracked startups. Fintech alone accounted for 111 regional deals and $1.3 billion of capital, per DealStreetAsia, with Singapore-domiciled entities capturing most of it.
Two features get overlooked. The Start-Up Tax Exemption explicitly excludes investment holding companies and property developers, so founders using Singapore as a pure holding wrapper without operating substance don’t see the effective rate fall. And Singapore has implemented the OECD’s Pillar Two regime (the Income Inclusion Rule plus a Domestic Top-up Tax) through the Multinational Enterprise (Minimum Tax) Act 2024. The law took effect for financial years starting on or after 1 January 2025 and applies to groups above €750 million in consolidated revenue. A small number of Asian startups today. Not a small number in five years.
British Virgin Islands
The British Virgin Islands (BVI) had 361,747 active companies as of 30 September 2025. The territory’s population is under 32,000. Q3 2025 alone added 8,348 incorporations, the best quarter since 2022 and up 19 percent on the prior three months, according to the BVI Financial Services Commission’s statistical bulletin.
The draw is unchanged. Zero corporate tax on non-BVI income. English common law, with a bench of commercial judges who have seen more cross-border restructurings than most London firms, and a dedicated Commercial Court that Chinese private equity funds have been known to specifically request in dispute resolution clauses. Incorporation costs that, across the four jurisdictions compared here, remain the cheapest by a comfortable margin.
What has changed is what gets filed, and where.
A rewrite of the beneficial ownership regulations took effect on 2 January 2025. BVI companies incorporated after that date now file beneficial ownership data with the Registrar, through the online VIRRGIN platform, within 30 days. Entities that existed before the cutoff had until 1 January 2026. A July 2025 amendment went further, introducing a “legitimate interest” access regime expected to go live from April 2026. The category is broad enough to cover journalists, NGOs, and compliance teams, for beneficial owners at 25 percent or above.
The BVI is still markedly more private than Singapore, Hong Kong, or the UK, all of which run public director and shareholder registers. For Chinese and Indian founders running a BVI top-co as the feeder for an eventual US listing, the new regime is an irritant, not an existential problem. Working guides on BVI company formation now treat the 30-day filing as a day-one task rather than a post-close cleanup.
Cayman Islands
Cayman is where the money managers live.
The Exempted Limited Partnership is the structural bedrock of nearly every Asian venture fund of any scale. A GP runs the fund, limited partners get pass-through treatment, the vehicle itself carries no tax drag. The 2026 Revision of the International Tax Co-operation (Economic Substance) Act, issued earlier this year, consolidated five years of amendments without adding substantive new obligations, per an analysis from the offshore firm Loeb Smith.
The tax profile is straightforward. Cayman issues a statutory guarantee, currently twenty years and extendable on application, covering corporate, income, capital gains, and withholding tax. Courts apply English common law. The Privy Council in London is the final appellate forum, which matters when you’re enforcing against a counterparty in, say, Indonesia. Shareholders and directors don’t appear in any public register.
As of March 2025, 286 Chinese companies were listed on the three largest US stock exchanges, up from 250 in 2021, per the US-China Economic and Security Review Commission. Most use Cayman Exempted Companies as the top holding entity. For Southeast Asian founders mapping a US SPAC or a traditional IPO route, underwriter counsel and investor legal teams have seen the structure a thousand times. That alone takes weeks out of the timeline.
Running cost is where Cayman stings. Practitioner material on Cayman exempted company setup places annual government fees and registered office charges several multiples above the BVI equivalent, and none of it buys the operating-business tax relief Singapore provides. Cayman is the right answer for a fund. It is almost never the right answer for a revenue-generating startup that hasn’t yet reached the point of a US listing.
Hong Kong
Hong Kong is the only jurisdiction on this list that taxes operating profits: 8.25 percent on the first HK$2 million of assessable profits, 16.5 percent above that. Chinese subsidiary dividends flow up to a Hong Kong parent tax-free under the participation exemption, once the 12-month holding requirement is met and given that China’s 25 percent corporate rate clears the 15 percent “similar tax” bar with room to spare.
The Foreign-Sourced Income Exemption regime is the one thing everyone in the jurisdiction talks about. Introduced on 1 January 2023 and expanded on 1 January 2024, FSIE deems four categories of offshore passive income (interest, dividends, equity disposal gains, and IP income) to be Hong Kong-sourced and taxable if the recipient is a multinational enterprise member carrying on business in Hong Kong and fails to meet economic substance, participation, or nexus tests. The Inland Revenue Department’s official FSIE guidance sets out the carve-outs, including a softer substance test for pure equity holding entities.
Non-MNE Hong Kong companies, those under the €750 million consolidated revenue bar, sit outside FSIE entirely and carry on enjoying the territorial system. For most Asian startups, FSIE is a post-IPO parent problem, not a Series B founder problem.
Hong Kong came off the EU’s international tax cooperation watchlist on 20 February 2024, once Brussels accepted the FSIE amendments aligned with the Code of Conduct Group’s updated guidance. A separate patent box regime offers a 5 percent concessionary rate on qualifying income from eligible IP, aimed at R&D and commercialisation within the territory. It is worth considering for biotech and deep-tech founders thinking about where IP ownership should live. The banking infrastructure, the capital markets bench, and the direct treaty access to mainland China remain Hong Kong’s genuine advantages. For a Shenzhen-headquartered startup with customers across ASEAN, no other jurisdiction on this list comes close on operational convenience. They still outweigh most of the compliance noise.
The composite answer
Serious Asian founders no longer pick one jurisdiction. The common stack today: a Cayman or BVI top holding company, a Singapore operating subsidiary, country-specific entities where operations actually sit. Pillar Two, beneficial ownership registers, and expanded substance tests have made the single-jurisdiction offshore wrapper that worked in 2015 unworkable for anyone past Series B. The decision has shifted from “cheapest to incorporate” to “least likely to blow up a fundraise three years from now.” Different question. Harder question. Not going back.
