The tax treatment of asset management is a well-known field of discussion between literature and case law in the sector of all taxes on income, especially with regard to the distinction of commercial and non-commercial activities within the asset management. This thesis leads to a new way of distinction, originating from the asset management of the public sector. It closely examinates the tax exemption of the public sector and develops the idea of a general tax exemption of all asset management-related activities. The thesis expressly covers the "tax spheres" of the public and the private sector and tries to implement a new structure of taxation of asset management in tax law.