In December 2016 the Ministry of Finance (MOF) and State Administration of Taxation (SAT) issued Circular Caishui  No.140 (Circular No.140). Article 4 of the circular provides that managers for asset management products shall be treated as VAT taxpayers. Shortly afterwards, in January 2017, the MOF and SAT issued Circular Caishui  No.2 (Circular No.2), postponing the implementation date of the clarified tax treatment to 1 July 2017. In view of the tight timeline, industry players should start their preparations without further delay. Preparation steps may be divided into three categories – (i) product design and (ii) product operation, which focus on upgrading business procedures, as well as (iii) tax filing.