Foreign pool of assets (Vermögensmasse ausländischen Rechts)

German 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 settlor transfers to a third party who shall administer it for a specific purpose and which are not attributable to the settlor or the beneficiary persuant to § 39 AO (fiduciary arrangement). If the settlor, his relatives and/or their family members in the meaning of § 15 AO have at least a 50% interest in trust, it is referred to as foreign family pool of assets in the German Foreign Transaction Tax Act and special rules for the attribution of trust income to a German resident beneficiary apply. As for inheritance and gift tax purposes, special rules apply for foreign pools of assets that have as their purpose to  bind assets.