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Singapore Substance Checklist

A practical screen for companies using Singapore as a regional or global base. Five questions that reveal whether the operating model will survive scrutiny from investors, banks, customers and regulators.

Question 01

Which strategic decisions are actually made in Singapore?

Can you name the decisions that are made here — and by whom? Board resolutions, capital allocation, pricing, hiring and partnership approvals all count. If the answer is "most things are decided in [home market]", that is a substance gap.

Question 02

Which senior roles are Singapore-based?

Nominal directors and resident directors provided by corporate secretaries do not create substance. Real substance requires executives who live and work here, manage people here and are responsible for real outcomes here.

Question 03

Where are IP, data, compliance and customer contracts governed?

Which legal entity holds key IP? Where is customer data stored and processed? Which jurisdiction's law governs customer contracts? These are the questions a bank, investor or acquirer will ask in due diligence.

Question 04

What local jobs, suppliers, partners or capability pathways are created?

Singapore's value proposition depends on real economic contribution. Procurement from local suppliers, Singapore-resident employees, partnerships with local institutions and training programmes all strengthen the substance case.

Question 05

Can the company explain its origin, control and operating model without ambiguity?

If the company's origin, ownership or control structure is complex or sensitive, can it be explained clearly — in English, to a sceptical counterparty — in under five minutes? If not, that is a narrative gap as much as a governance one.

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