On 3 October 2026, the Malaysian Government gazetted eleven pieces of subsidiary legislation listed relating to Pulau 1 of the Forest City Special Financia Zone (“Pulau 1 FCSFZ”).¹] The name of each subsidiary legislation and their commencement date or effective period are set out in columns (1) and (2) respectively of the Table below:
 

(1) Name of subsidiary legislation	(2) Commencement date / effective period
Income Tax (Single Family Office Incentive Scheme) (Pulau 1 of Forest City Special Financial Zone) Rules 2025 (“P.U.(A) 350/2025”)	1 September 2024
Income Tax (Single Family Office Incentive Scheme) (Pulau 1 of Forest City Special Financial Zone) (Exemption) Order 2025 (“P.U.(A) 351/2025”)	1 September 2024
Stamp Duty (Single Family Fund Company) (Pulau 1 of Forest City Special Financial Zone) (Exemption) Order 2025 (“P.U.(A) 352/2025”)	1 September 2024
Stamp Duty (Instrument of Loan or Financing Agreement in relation to Individual) (Pulau 1 Forest City Special Financial Zone) (Remission) Order 2025 (“P.U.(A) 353/2025”)	1 September 2024 until 31 December 2034
Stamp Duty (Instrument of Transfer in relation to Individual) (Pulau 1 of Forest City Special Financial Zone) (Remission) Order 2025 (“P.U.(A) 354/2025”)	1 September 2024 until 31 December 2034
Stamp Duty (Instrument of Loan or Financing Agreement in relation to Qualifying Person) (Pulau 1 of Forest City Special Financial Zone) (Remission) Order 2025 (“P.U.(A) 355/2025”)	1 September 2024 until 31 December 2034
Stamp Duty (Instrument of Transfer in relation to Qualifying Person) (Pulau 1 of Forest City Special Financial Zone) (Remission) Order 2025 (“P.U.(A) 356/2025”)	1 September 2024 until 31 December 2034
Income Tax (Income of Non-resident Person) (Pulau 1 of Forest City Special Financial Zone) (Exemption) Order 2025 (“P.U.(A) 357/2025”)	1 September 2024
Real Property Gains Tax (Pulau 1 of Forest City Special Financial Zone) (Exemption) Order 2025 (“P.U.(A) 358/2025”)	1 September 2024
Income Tax (Industrial Building Allowance) (Pulau 1 of Forest City Special Financial Zone) Rules 2025 (“P.U.(A) 359/2025”)	From Year of Assessment 2024
Income Tax (Deduction of Cost for Relocation of Business) (Pulau 1 of Forest City Special Financial Zone) Rules 2025 (“P.U.(A) 360/2025”)	1 September 2024

 
In this first of a three part article, we will provide a summary of the main requirements under the three pieces of subsidiary legislation that deals specifically with single family offices to be established in Pulau 1 FCSFZ, namely P.U.(A) 350/2025, P.U.(A) 351/2025 and P.U.(A) 352/2025.
 
It is to be noted that, subject to compliance with the relevant conditions, a single family fund company will also be eligible for the benefits under P.U.(A) 355/2025 to P.U.(A) 357/2025, P.U.(A)359/2025 and P.U.(A) 360/2025. These subsidiary legislation will be dealt with in the subsequent parts of this article.
 
Parts 2 and 3 of this article can be accessed here and here.
 
Meaning of single family
 
The expression “single family” is defined in identical terms in P.U.(A) 350/2025, P.U.(A) 351/2025 and P.U.(A) 352/2025, and means a family whose members are individuals who are lineal descendants of a single ancestor and includes (a) the spouse; (b) the biological child; (c) the stepchild; and (d) the child adopted in accordance with any written law.
 
P.U.(A) 350/2025 – Tax exemption for qualifying activity
 
Rate of income tax
 
Rule 8 of P.U.(A) 350/2025 provides that the rate of income tax for the specified years of assessment on the chargeable income of an approved company which carries on a qualifying activity under the Single Family Office Incentive Scheme shall be 0% for the first period of 10 years of assessment (“YA”) and for the following period of 10 YAs.
 
The key terms under rule 8 are as follows: 

1. Approved company which refers to a qualifying company which has been granted an approval for the Single Family Office Incentive Scheme under rule 5 of P.U.(A) 350/2025. 
   For the purposes of the definition of an “approved company”, a qualifying company is a single family fund company which is: (a) incorporated under the Companies Act 2016 (“CA”) and resident in Malaysia; (b) wholly owned, directly or indirectly, by a member of a single family; (c) operating in Pulau 1 FCSFZ; and (d) established solely for the purpose of holding the asset and investment activity for the interest of members of a single family.
   A qualifying company will not be a qualifying company if in a specified year of assessment, it has made a claim or been granted an exemption or incentive under any of paragraphs (a) to (e) of rule 3(2) of P.U.(A) 350/2025; and 

2. Qualifying activity is the following activity undertaken by a qualifying company: (a) holding of assets for the interest of the single family; and (b) investment activity for the interest of the single family, including buying or selling of assets and trading of capital market products; 
3. Specified years of assessment refers to the first period of 10 consecutive YAs and the subsequent period of 10 consecutive YAs for the implementation of the Single Family Office Incentive Scheme, commencing from the YA in which the approved company obtains the first certification from the Securities Commission Malaysia (“SC”) under rule 6(a) of P.U.(A) 350/2025. 

Application for Single Family Office Incentive Scheme
 
A qualifying company may apply for the Single Family Office Incentive Scheme to the Minister of Finance (“Minister”) through the SC from 1 September 2024 to 31 December 2034. The Minister may: (a) approve the application and issue the approval letter to the approved company subject to the conditions specified in rule 6 or other conditions as he thinks fit; or (b) refuse the application.
 
Rule 6 of P.U.(A) 350/2025 requires an approved company to comply with the conditions imposed by the Minister, which shall include the following: 

1. for each year of the first period of 10 YAs, the approved company shall obtain a certification from the SC that the approved company: (i) has employed at least two full-time employees whom one is a professional investor with a minimum salary of RM10,000; (ii) has not used bank deposits for local investment; (iii) at the end of the YA, (A) has incurred an annual local operating expenditure of not less than RM500,000; (B) has assets under its management of not less than RM30 million; and (C) has made a local investment of not less than RM10 million or 10% of the assets under its management referred to in paragraph (a)(iii)(B), whichever is the lower; and (iv) has not carried on any other business in Malaysia; 
2. for each year for the following period of 10 YAs, the approved company shall obtain a certification from the SC that as at the end of the YA, the approved company has: (i) assets under its management of not less than RM50 million; and (ii) made a local investment of not less than RM10 million or 10% of the assets under its management referred to in paragraph (b)(i), whichever is the greater; (iii) employed at least four full-time employees; and (iv) incurred an annual local operating expenditure of not less than RM650,000; 
3. the approved company shall comply with the conditions provided for under section 65B of the Income Tax Act 1967 (“ITA”); and 
4. the approved company shall comply with any guidelines issued by the SC. 

Commencement date
 
P.U.(A) 350/2025 is deemed to have come into operation on 1 September 2024.
 
P.U.(A) 351/2025 – Tax exemption for profits for transfer of unlisted shares by an eligible transferor to a single family fund company
 
Tax exemption
 
Paragraph 3 of P.U.(A) 351/2025 exempts a company, limited liability partnership, trust body or co-operative society which is wholly owned, directly or indirectly, by a member of a single family from the payment of income tax on chargeable income from gains or profits received from the disposal of shares of a company incorporated in Malaysia which is not listed on Bursa Malaysia Securities Berhad to a single family fund company.
 
Single family fund company
 
For the purposes of P.U.(A) 351/2025, a “single family fund company” refers to a company incorporated under the CA 2016 and resident in Malaysia which is: (a) wholly owned, directly or indirectly, by a member of a single family; (b) operating in Pulau 1 FCSFZ; and (c) established solely for the purpose of holding the asset and investment activity for the interest of members of a single family.
 
Conditions for exemption
 
The exemption under paragraph 3 of the Rules is subject to the following conditions: 

1. the single family fund company shall obtain a certification letter from the SC; 
2. the disposal of shares shall be made (i) to a single family fund company within 12 months from the date the certification letter issued by the SC; and (ii) within the period from 1 September 2024 to 31 December 2034; and 
3. the ultimate beneficial owner of the company, limited liability partnership, trust body or co-operative society and the ultimate beneficial owner of the single family fund company shall consists of members of the same single family. 

Loss from disposal of shares
 
Any loss from the disposal of shares referred to in paragraph 3 by a company, limited liability partnership, trust body or co-operative society within the period from 1 September 2024 to 31 December 2034 shall be disregarded for the purposes of sections 65E(5) and 65E(6) of the ITA.
 
Non-application
 
P.U.(A) 351/2025 shall not apply to (a) a disposal of shares of a company incorporated in Malaysia which is not listed on the stock exchange where gains or profits from the disposal of shares is chargeable to tax as a business income under paragraph 4(a) of the ITA; or (b) a company, limited liability partnership, trust body or co-operative society which has been granted a tax exemption under section 127(3)(b) or 127(3A) of the ITA in respect of the same disposal of shares.
 
Commencement date
 
P.U.(A) 351/2025 is deemed to have come into operation on 1 September 2024.
 
P.U.(A) 352/2025 – Stamp duty exemption for transfer of qualifying asset by an eligible transferor to a single family fund company
 
Stamp duty exemption
 
Paragraph 3(1) of P.U.(A) 352/2025 exempts from stamp duty, an instrument of transfer of a qualifying asset to single family fund company by a member of a single family or by a company or trust body which is wholly owned, directly or indirectly, by a member of the single family.
 
For the purposes of paragraph 3(1), a single family fund company is a single family fund company which operates in Pulau 1 FCSFZ and is certified by the SC.
 
Conditions of exemption
 
The exemption under P.U.(A) 352/2025 is subject to the following conditions: 

1. the instrument of transfer of the qualifying asset must be executed from 1 September 2024 to 31 December 2034; 
2. the said instrument of transfer shall be executed within one year from the date the certification letter is issued by the SC; and 
3. the single family fund company shall attach the certification letter referred to in paragraph (b) above. 

Commencement date
 
P.U.(A) 352/2025 is deemed to have come into operation on 1 September 2024.
 
 
Article by Sheba Gumis (Partner) and Joey Tiw (Senior Associate) of the Corporate Practice of Skrine.