Foreign pool of assets (Vermögensmasse ausländischen Rechts)

The law uses the term "foreign pool of assets" in various places (including § 15 AStG, § 3 ErbStG, § 7 ErbStG). The term refers to assets which the original owner transfers to a third party who shall administer it for a specific purpose and which the original beneficiary can no longer complete control of. The pool of assets does not have to be a legal entity. When the term was introduced, the legislator primarily thought of trusts. If the settlor, his relatives and/or their descendants have at least a 50% interest in trust, it is referred to as foreign family pool of assets

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