Holding Companies & Special Purpose Vehicles

Under Singapore’s Personal Data Protection Act (PDPA), organizations that collect, use, or disclose personal data as part of their operations are required to designate at least one individual to be responsible for ensuring compliance with the PDPA. This individual is known as the Data Protection Officer (DPO). Designating a DPO is an important step for organizations to ensure that they are complying with the PDPA, protecting the privacy of individuals’ personal data and reporting data breaches to the Personal Data Protection Commission (PDPC). In addition to being a legal requirement, designating a DPO can also help organizations to build trust with their customers and stakeholders by demonstrating their commitment to protecting personal data. The non-appointment of a DPO can be followed by penalties of up to SGD 5,000.

The RORC is a register containing the particulars of the company’s registrable controller(s), also commonly known as beneficial owner(s). The Registrable controller is identified as the beneficial owner (individual or corporate entities) of the company that: Have an interest in > 25% of shares in a company; or Hold > 25% of members’ voting rights in a company; or Can exercise significant influence or control over a company. The Information on the RORC must be lodged with ACRA within two business days after the entity has set up its RORC, and any change shall be updated.

The RORC is a register containing the particulars of the company’s registrable controller(s), also commonly known as beneficial owner(s). The Registrable controller is identified as the beneficial owner (individual or corporate entities) of the company that: Have an interest in > 25% of shares in a company; or Hold > 25% of members’ voting rights in a company; or Can exercise significant influence or control over a company. The information on the RORC must be lodged with ACRA within two business days after the entity has set up its RORC, and any change shall be updated.

The audit exemption in Singapore is allowed for a company meeting 2 of the 3 criteria: total annual revenue ≤ $10m; total assets ≤ $10m; no. of employees ≤ 50. As part of a group; the company and the group shall meet 2 of the 3 criteria on a consolidated basis for the past 2 financial years.