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Sung, Min Young
Practice Areas
Introduction
Min Young Sung is a Partner at Yulchon who practices primarily in the areas of tax litigation and tax planning and strategy focued on international taxation. He received his LL.M. from UC Berkeley, LL.B. and M.A. from Seoul National University, where he specialized in tax law.
- 2017 UC Berkeley School of Law, LL.M.
- 2012 Seoul National University, M.A.
- 2009 Judicial Research and Training Institute, the Supreme Court of Korea
- 2007 Seoul National University, LL.B.
- 2012-present Yulchon LLC
- 2017-2018 Anderson Mori & Tomotsune
- 2017 Nishimura & Asahi, Tokyo, Japan
- 2009-2012 Judge Advocate, Republic of Korea Army
- 2009 Republic of Korea
Korean, English, Japanese
Representative Matters
- 2023 Successfully represented a U.S. ICT company in a case over beneficial ownership of Dividend income under the Tax Treaty between Korea and Austria
- 2023 Represented a global fashion company and successfully obtained a re-audit decision from the Tax Tribunal in respect of the transfer pricing tax assessment issued as a result of a tax audit on the company, and also successfully assisted the company with the re-audit
- 2022 Represented the Korean subsidiary of a foreign semiconductor packaging company and won the case regarding the tax exemption available for foreign invested companies under the Special Tax Treatment Control Act
- 2022 Represented a Korean airline company and successfully defended a tax audit in relation to the corporate withholding tax on payments for aviation maintenance services
- 2021 Successfully represented a U.S. pharmaceutical company in a tax audit regarding royalty income generated from Korean sources
- 2021 Successfully represented a U.S. ICT company in a case over beneficial ownership of royalty income under the Tax Treaty between Korea and Hungary
- 2020 Successfully represented a U.S. hotel chain in a lawsuit seeking tax reduction or exemption for foreign-invested company under the Restriction of Special Taxation Act
- 2020 Represented H, a semiconductor company, obtained a favorable decision in a civil case involving the value added tax
- 2017 Successfully represented a big U.S. private equity fund in a case over taxation on permanent establishment
- 2017 Successfully represented a Japanese company S in a case over a withholding tax rate on inter-company dividends under Korea-Japan Tax Treaty
- 2016 Successfully represented a Japanese company A’s subsidiary in Korea in a claim for rectification in corporate tax
- 2015 Provided tax advisory service to Visteon with respect to its sale of shares in Hanon Systems
- 2015 Successfully represented a Finnish company W’s subsidiary in Korea in a case over business consulting fees
- 2014 Successfully represented Korean subsidiary of German automobile components manufacturer C in a case over customs duty
- 2013 Conducted research commissioned by Ministry of Economy and Finance on reformation of tax law (on value added tax)
News/Publications
The Korean tax authority’s attempt to seize the upper hand over foreign corporate taxpayers, International Tax Review (Co-Author)(2023) download
Beneficial ownership in South Korea: Tax audit appeal and planning opportunities, International Tax Review (Co-Author) (2022) download
韓国における最近のPE認定課税に対する執行強化の状況とその対応方法について, Monthly Journal International taxation (Japan), Feb. Issue, 2020 (2020)
Standard and Limited Permission for Duplicate Tax Audit, Monthly Tax Journal (Wolgan Jose), Oct. Issue, 2015 (2015)
Application of International Tax Treaty to a Person who Lives in Two Countries and Criteria to Determine Residency, Monthly Tax Journal (Wolgan Jose), Feb. Issue, 2015 (2015)
Can Income Gained from Share Transfer by Entities including U.S. Limited Liability Companies be Tax-Exempt in accordance with the Korea-U.S. Tax Treaty?, Monthly Tax Journal (Wolgan Jose), Oct. Issue, 2014 (2014)
Termination of Residential Real Estate Purchase Agreement and Ex Post Events of Rectification Claim, Monthly Tax Journal (Wolgan Jose), May. Issue, 2014 (2014)
Ex Post Events after Formation of Tax Liability that Affects Initial Obligation for Corporate Tax, Monthly Tax Journal (Wolgan Jose), Feb. Issue, 2014 (2014)
High Sales Agent Fee and Criteria to be Determined as Necessary Expense for Transfer Income, Sekyoung Newspaper, No. 373 (2013)
Reason for Objection to Disposition of Rectification for Additional Taxation in the Appeal thereagainst, Monthly Tax Journal (Wolgan Jose), Aug. Issue, 2013 (2013)
Basis of Calculating Surcharge Should be Shown in Tax Payment Notice, Monthly Tax Journal (Wolgan Jose), Dec. Issue, 2012 (2012)
Whether Damages for Accident Assumed in Total by Subcontractor under Special Arrangement with Contractor is Considered Entertainment Expense, Sekyoung Newspaper, No. 368 (2012)
Range of Additional Tax Amount that can be Cancelled Before the Period for Rectification Claim Terminates, Sekyoung Newspaper, No.360 (2012)
Can the Principle of Substantial Taxation be Applied When Interpreting a Tax Treaty?, Monthly Tax Journal (Wolgan Jose), Jul. Issue, 2012 (2012)
