Chief Editor November 18 2023

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Man Fined S$1.4 Million for Operating Illegal Short Term Rental Across 19 Singapore Properties

A Singaporean man, Too Kim Lin, aged 53, has been fined a staggering S$1,428,000 by a district court for violating the Planning Act. His illicit venture involved managing 19 residential properties for illegal short term rent and enlisting the help of four former maids to oversee the operations.

Too Kim Lin admitted guilt to 11 charges related to leasing residential properties for short-term accommodation, defined as stays lasting less than three consecutive months. The court, in a judgment made available on November 15, considered an additional eight charges concerning eight other properties during sentencing.

The specific locations of the properties were withheld in the judgment, except for one mentioned explicitly—a unit on the 29th floor of the V on Shenton condominium.

Court documents revealed that Too orchestrated a sizable illegal short-term accommodation enterprise, actively scouring rental platforms to expand his portfolio in the financial district. To distance himself from the transactions, he employed various individuals, including his older brother and mother, to enter into tenancy agreements on his behalf, never using his own name.

When questioned by property owners or agents, explanations were given that the properties were intended for legitimate purposes, such as housing Too's girlfriend or elderly mother. In reality, after securing the tenancies, Too sublet the units for profit.

His modus operandi included listing and advertising the units on platforms like Airbnb,, and HomeAway. The income generated from subletting was used to cover the monthly lease payments for the properties. Additionally, Too engaged four of his former maids to run errands for his illegal business, such as restocking supplies and toiletries.

To avoid detection, Too employed various tactics, using multiple mobile numbers and instructing guests not to go directly to the properties. Instead, they were to contact him or an accomplice, meet near the properties, and then be guided through a car park or side entrance to bypass security guards.

Complaints and feedback from the managing agent of one condominium and two landlords raised suspicions about the high turnover of visitors and potential short-term rentals.

Over the period from February 1, 2018, to October 30, 2019, Too accumulated a total revenue of S$1.47 million from providing short-term accommodation at the 19 properties. After deducting expenses, his profit amounted to approximately S$768,000.

During the legal proceedings, the prosecution sought a fine ranging from S$1.54 million to S$1.76 million, aiming to disgorge the illegal earnings and impose a punitive penalty. Too's defense team, represented by Mr. Nicholas Yong Yoong Han and Mr. Andrew Wong Wei Kiat of Fortis Law, advocated for a lower fine of S$756,860, citing estimated monthly expenses of S$410 per property for utilities, internet, and cleaning fees. However, the judge noted a lack of evidence supporting these claimed expenses.

The debate extended to the potential jail term in case Too couldn't pay the fine. The defense proposed a "conversion rate" of one week's jail for every S$10,000 fine, while the prosecution suggested one week's jail for every S$8,800 in fines. The judge found the defense's conversion rate reasonable, resulting in a jail term not significantly different from the prosecution's proposed equivalent default jail term.

Therefore Too will have to serve a jail term of 142 weeks, which is approximately two years and nine months if he cannot pay the fine. 

Despite the imposed fine, Too Kim Lin intends to appeal his sentence, and the execution of the sentence has been deferred until after the appeal is heard.