Key Takeaways

  • Startups based in Singapore raised S$5.9 billion across 472 venture deals in 2025, in a year when Southeast Asia's total deal count fell to one of its lowest levels in more than 6 years.
  • Hong Kong finished 2025 as the world's top IPO venue, with HK$274.6 billion raised across 106 new listings, most of it from mainland Chinese tech and biotech companies.
  • Singapore's tax treaty network covers around 100 jurisdictions against Hong Kong's 60 signed agreements, and that gap sets the withholding tax on every cross-border royalty an IP holding company collects.
  • Both cities now tax qualifying IP income at a 5% concessionary rate under BEPS nexus rules, so the treaty network separates them more than the incentive headline does.
  • Savvy Platform sets up the Singapore structure for tech founders: incorporation, nominee director, company secretary, bank account support and the EntrePass or Employment Pass application.

A SaaS or deep-tech founder raising from ASEAN, Indian or Western investors is better served incorporating in Singapore. A founder building toward a Hong Kong listing or raising mainland Chinese capital is better served in Hong Kong. The 2025 capital data draws that line clearly, and the treaty and visa comparisons follow it.

Savvy Platform incorporates Singapore companies for foreign founders, so this article argues the Singapore case where the numbers support it and gives Hong Kong its wins where they're real. SavvyStart covers incorporation, the nominee director, the company secretary and bank account support in one package.

 

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Two Cities, Two Pools of Capital

The venture money and the listing money sit in different places. Singapore-based firms raised S$5.9 billion across 472 deals in 2025, per the Singapore Venture Funding Landscape report published by EY-Parthenon with Enterprise Singapore. DealStreetAsia's full-year report puts Southeast Asia's equity funding at US$5.37 billion, with value rebounding to US$3.51 billion in H2 from US$1.86 billion in H1.

Hong Kong's 2025 story ran through the stock exchange instead of the venture market. HKEX reported HK$274.6 billion raised from 106 new listings as of 19 December 2025, enough to make Hong Kong the world's top IPO venue, with 4 of the world's 10 largest IPOs.

2025 capital signal

Figure

What it tells a founder

Singapore venture funding

S$5.9 billion across 472 deals

The region's venture rounds close into Singapore entities

Southeast Asia equity funding

US$5.37 billion, H2 rebound to US$3.51 billion

The regional market contracted, then turned in H2

Hong Kong IPO proceeds

HK$274.6 billion from 106 listings, world No. 1

Mainland tech and biotech drove the listing boom

Singapore IPOs by mid-July 2025

3, per Fortune

Singapore exits run through trade sales or foreign exchanges

Chapter 18C listings since 2023

14 companies, HK$28.4 billion raised

Hong Kong has a working public-market route for deep tech

The composition of Singapore's 2025 deals matters for tech founders specifically. The EY-Parthenon report counts AI startups at 42.8% of the year's 472 deals, with deep tech's share of deal value reaching 24.7%, so the capital that stayed active through the downturn concentrated in the AI and deep-tech segments this comparison serves.

The practical read: a startup selling into ASEAN or India raises from funds that operate out of Singapore and price rounds into Singapore private limited companies. A startup courting mainland capital, or planning an HKEX listing, wants the Hong Kong structure those investors underwrite.

IP Holding: Treaty Reach Decides the Withholding Tax

A tech company's IP holding entity earns royalties and licence fees across borders, and every one of those payments passes through a withholding tax gate set by treaty. Singapore's network of tax agreements covers around 100 jurisdictions, per the list IRAS publishes. Hong Kong has signed comprehensive double taxation agreements with 60 jurisdictions as at September 2026, per the Financial Services and the Treasury Bureau, which also lists negotiations underway or scheduled with 16 more.

The count sounds abstract until the first licence deal lands in a non-treaty market and the payer's tax authority takes its full domestic cut off the top.

IP holding factor

Singapore

Hong Kong

Treaty coverage

Around 100 jurisdictions

60 signed CDTAs

Domestic WHT on royalties paid out to non-residents

10%, per PwC

Effectively 2.475% to 4.95%, per PwC

WHT on dividends to shareholders

None

None

IP box rate on qualifying income

5%, 10% or 15% under the IDI

5% under the patent box

Hong Kong's outbound royalty rate is lower. The exposure runs the other way: when your customers' jurisdictions withhold tax on royalties they pay you, only a treaty claws it back. A licensing flow from a country that has a treaty with Singapore and none with Hong Kong keeps more of every dollar in the Singapore structure, and with 100 covered jurisdictions against 60, that situation comes up often for a global SaaS or licensing business.

The IP Boxes: 5% in Both Cities, Through Different Doors

Hong Kong's patent box, enacted in July 2024 and applying from the year of assessment beginning 1 April 2023, taxes the qualifying portion of eligible IP income at 5%, per the Inland Revenue Department. Eligible IP covers patents, copyrighted software and plant variety rights, and the regime reaches beyond royalties to embedded IP income inside product and service sales.

The qualifying portion follows the BEPS Action 5 nexus formula the IRD publishes: eligible R&D expenditure, uplifted by 30% and capped at 100% of total expenditure on the IP, sets the fraction of income that gets the 5% rate. In plain terms, the more of the development your own company carried out, the more of the income qualifies.

Singapore's equivalent is the IP Development Incentive, which PwC's tax summary describes as a reduced rate of 5%, 10% or 15% on a percentage of qualifying IP commercialisation income, determined under the same modified nexus approach. The difference is access. Hong Kong's patent box is a tax election any qualifying taxpayer can make. Singapore's IDI is an awarded incentive, approved by the Economic Development Board with commitments attached.

For an early-stage startup with no profits yet, neither regime changes year 1. Both matter at the point your licensing income turns material, which is exactly when the treaty network above starts deciding how much of that income survives the border.

Hong Kong's Real Advantages: the HKEX Track and Subsidised Incubation

Hong Kong offers a tech founder 2 things Singapore can't match. The first is a working public market for tech listings, built on Chapter 18C of the HKEX Listing Rules, in force since 31 March 2023:

  • Commercial specialist technology companies list at an expected market capitalisation of HK$4 billion with HK$250 million of revenue, under thresholds modified in August 2024
  • Pre-commercial companies list at HK$8 billion with no revenue test
  • 14 companies had listed under 18C by 31 March 2026, raising HK$28.4 billion, within the 88 biotech and specialist technology listings HKEX counts since its rule reforms began
  • The market behind them is liquid: average daily cash turnover of HK$255.8 billion in the first 11 months of 2025, up 95% year on year, now tracked by a Tech 100 Index

Fortune reported Singapore's exchange at 3 IPOs by mid-July 2025. If a liquid home-market listing sits anywhere in your 10-year plan, Hong Kong has one and Singapore doesn't.

The second is subsidised incubation with real money behind it:

  • Cyberport's incubation programme provides up to HK$500,000 over 24 months, on-site or off-site, per StartmeupHK, InvestHK's startup portal
  • Hong Kong Science and Technology Parks runs a 3-year incubation programme with up to HK$1.29 million for technology and business development expenses, plus lab access and a rental subsidy

Singapore backs first-time founders through the Startup SG umbrella under Enterprise Singapore, and the Hong Kong pair stands out for the size of its published support ceilings. A deep-tech founder who needs subsidised lab space now and a Greater China listing later has a coherent all-Hong Kong path.

The Residency Route Through Your Own Company

Singapore's answer is structural: both of its founder visas run through the company you're incorporating. The Ministry of Manpower publishes the criteria.

 

EntrePass

Employment Pass (own company)

Shareholding

At least 30% of the company

No minimum

Salary floor

None

S$5,600, rising to S$6,000 from 1 January 2027

Points test

No, innovation criteria instead

Yes, 40 points under COMPASS

Timing

Apply before registering the company, or while it's still assessed on initial criteria; a company more than 12 months old at application faces renewal criteria

Any time the company can sponsor you

Typical fit

Funded or IP-holding founders

Founders paying themselves a market salary

The EntrePass innovation criteria map directly onto a tech startup's assets: at least S$100,000 raised in a single funding round, IP registered with an approved national IP institution, a research collaboration, or backing from a government-recognised or internationally renowned incubator, with MOM naming Y Combinator as an example.

The Employment Pass route trades those criteria for a payroll test. Your company pays you at least the qualifying salary, S$6,200 in financial services against S$5,600 elsewhere, both floors rising with age and moving to S$6,600 and S$6,000 from 1 January 2027, and your application scores at least 40 points under COMPASS.

Either pass makes you Singapore-resident, and a resident founder replaces the nominee director their company needed on day 1. Hong Kong grants residency through separate talent schemes, such as the Top Talent Pass, that don't attach to your company's structure.

How Savvy Platform Handles the Tech Founder's Setup

  • Incorporation with ACRA under the SavvyStart package, with the share structure investors expect to see at term-sheet stage
  • A nominee director through an ACRA-registered corporate service provider, covering the resident-director requirement until your own pass comes through
  • Company secretary and annual filings, so the entity stays clean for due diligence
  • Bank account support with Singapore's traditional banks and digital providers
  • Accounting and bookkeeping, keeping the numbers investor-ready between rounds
  • EntrePass or Employment Pass application, matched to whether your case runs on shareholding and funding or on salary and COMPASS points

Incorporate Where Your Investors Deploy

Incorporate where your next round's investors already deploy: Singapore for ASEAN, Indian and Western cap tables, Hong Kong for mainland capital and the HKEX track. The IP incentives have converged at 5%, so the treaty network, at around 100 jurisdictions against 60, is the durable tax difference for a licensing business.

If the Singapore side fits, the EntrePass decision comes first, since MOM assesses older companies against renewal criteria. Send Savvy an enquiry and scope the incorporation and pass application together.

 

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FAQ

Which city should a SaaS startup incorporate in to raise venture capital?

Singapore, if your investors are ASEAN-focused, Indian or Western funds. Singapore-based firms closed 472 venture deals worth S$5.9 billion in 2025, while Hong Kong's capital story ran through HKEX listings funded largely by mainland Chinese investors.

Do Singapore and Hong Kong both have a 5% tax rate on IP income?

Both can reach 5% on qualifying IP income under BEPS nexus rules. Hong Kong's patent box is an election open to any qualifying taxpayer from the year of assessment starting 1 April 2023, while Singapore's IP Development Incentive is awarded by the EDB at 5%, 10% or 15%.

Does the EntrePass have a minimum salary?

No. The EntrePass requires at least 30% shareholding and 1 innovation criterion, such as S$100,000 raised in a single round or registered IP. The Employment Pass through your own company carries the salary floor: S$5,600 now, S$6,000 from 1 January 2027.

Can a pre-revenue deep-tech company go public in Hong Kong?

Yes, under Chapter 18C of the HKEX Listing Rules, if it reaches an expected market capitalisation of HK$8 billion as a pre-commercial company. Commercial companies qualify at HK$4 billion with HK$250 million of revenue. 14 companies had listed under 18C by 31 March 2026.

Why does the treaty count matter for an IP holding company?

Withholding tax on royalties is set by the treaty between your company's jurisdiction and the payer's. Singapore's network covers around 100 jurisdictions against Hong Kong's 60 signed CDTAs, so royalty flows from non-treaty countries into a Hong Kong entity bear the payer country's full domestic withholding rate.

Sources

ANY QUESTIONS?

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