柳哲馨

  • 律师
  • T. +82-2-3404-0154
  • F. +82-2-3404-7687
  • E. cheolhyung.yu@bkl.co.kr

介绍

Cheolhyung Yu specializes in the practice areas such as: tax advisory & transactional, claim for reassessment, tax audit & Investigations, tax disputes, international tax, transfer pricing, local tax, tax ruling request & legislative consulting, administrative litigation, constitutional litigation and criminal tax litigation, etc.

As a legal advisor to the Tax and Customs Office of the Ministry of Finance and Economy, the National Tax Service and the Ministry of the Interior and Safety, Mr. Yu has been actively involved in improving tax systems in tax administration. He is also a tax expert who has handled tax consultations, representation of tax probes, and tax litigation for domestic and foreign companies and foreign investors for more than 20 years. As a member of the Pro Bono Committee of Bae, Kim & Lee LLC, he has devoted himself to pro bono activities in the areas of refugees, women and youth, and welfare over the past two decades.

履历

1997-至今 Bae, Kim & Lee LLC
1994-1997 Judge Advocate, Republic of Korea Army
其他经历
2024-至今 Chairman, Korea Local Tax Association
2024-至今 Legal Counselor, Ministry of the Interior
2023-至今 Member, Local Tax Development Committee, Ministry of the Interior and Safety
2020-至今 Adjunct Professor, Korea University Grauate School of Legal Studies
2020-至今 Civilian Member, Budget Performance-based Merits Deliberation Committee, Ministry of Economy and Finance
2020-至今 Chairman, Charity Consulting Committee, The Beautiful Foundation
2020-2021 Vice Chairman, Korean Society of Law
2020-2021 Member, Deliberation Committee for the Selection of Winner of Korea Legal Awards, Moneytoday
2020 Examiner, National Bar Examination, Ministry of Justice
2020 Chairman, Task Force Team for the Study of Issues involving the Imositition of VAT on Attoerneys' Fees, Seoul Bar Association
2020 Member, Deliberation Committee for the Selection of Winnner of Pro Bon Lawyer Award, MBN
2019-至今 Member, Committee for the Selection of Overseas Infrastructure Management Service Provider, National Pension Service
2019-至今 Adjunct Professor, Yonsei Universtiy Grauate School of Law
2019-至今 Member, Advisory Committee, Korea Institute of Local Finance
2019-2022 Member, Criminal Case Disclosure Deliberation Committee, Supreme Prosecutors' Office Republic of Korea
2019-2021 Member, Taxation System Enhancement Review Committee, Ministry of Economy and Finance
2019-2021 Member, Steering Committee for Practical Training for New Admittees to the Korean Bar, Korean Bar Association
2019-2021 Vice Chairman, Korean Bar Association
2019-2020 President, Korea Tax Research Forum
2018-至今 Auditor, The Happiness Foundation
2018-至今 Arbitrator, The Korean Commercial Arbitration Board
2018-至今 Auditor, Daekyo Culture Foundation
2018-至今 Vice Chairman, Korean Taxpolicy Association
2018-2019 President-Elect, Korea Tax Research Forum
2018 Member, Deliberation Committee for the Selection of Winner of Korea Legal Award, Moneytoday
2017-至今 Regular Director, Korea Public Administration Case Study Association
2017-至今 Vice Chairman, Tax Subcommittee in Practice Area-based Community, Seoul Bar Association
2017-至今 Member, Advisory Committee for Local Tax Relief, Korea Institute of Local Finance
2017-2023 Vice Chairman, Korea Local Tax Association
2017-2023 Member, Steering Committee, Legal Research Institute, Korean Bar Association
2017-2021 Member, Committee for Review of Interpretation of Local Tax Rules and Regulations, Ministry of the Interior and Safety
2017-2019 Member, Self-Evaluation Committee, Ministry of the Interior and Safety
2017-2019 Member, Social Investment Fund Management Review Committee, Seoul Metropolitan City
2017-2019 Vice Chairman, Seoul Bar Association
2017-2018 Member, Informationization Advisory Committee, Korea Public Finance Information Service
2017 Professor, 3rd Tax Law Training Course, Seoul Bar Association
2017 Member, Adivisory and Research Committee for the Enhancement of Judicial Selection System, Supreme Court of Korea
2017 Member, Oral Interview Evaluation Committee for Admission to Yonsei Universtiy Law School
2016-至今 Member , Dissertation Review Committee, Journal of International Fiscal Association Korea
2016-至今 Member, Dissertation Review Committee, Korean Journal of Taxation Research, Korean Academic Society of Taxation
2016-2021 Legal Counselor, Ministry of the Interior
2016-2018 Advisor, Promotional Committee for Establishment of Integrated Management System for finance Information Disclosure and Government Subsidies, Ministry of Economy and Finance
2016 Professor, the 19th Tax Law Training Course, Seoul Bar Association
2015-至今 Vice President, Korean Academic Society of Taxation
2015-至今 Auditor, Korean Parliamentarian Forum on Global health (KPFGH)
2015-至今 Member, Dissertation Review Committee, Tax Law, Korea Tax Research Forum
2015-至今 Columnist, Samil Informine
2015-至今 Auditor, Daesung Social Welfare Foundation
2015-至今 Director of Academic Affairs, International Fiscal Association Korea
2015-2023 Vice President, Korean Academic Society of Taxation
2015-2016 Civilian Member, Meritorious Achievement Review Committee, Ministry of the Interior
2015 Professor, 18th Tax Law Training Course, Seoul Bar Association
2014-至今 Advisor, The Korean Taxpayers Union
2014-至今 Auditor, Korean foundation for Rare Disease
2014-至今 Legal Counsel, Ministry of Economy and Finance
2014-至今 Finance Director and Auditor, Tax Law Association
2014-2020 Member, Alternative Investment Committee, National Pension Service
2014-2018 Vice Chairman, Korea Tax Research Forum
2014-2017 Legal Adviser for Tax Law, National Tax Service
2014-2017 Managing Director, Korea Public Administration Case Study Association
2014-2017 Member, Local finance Tax System Division, Policy Advisory Committee, Ministry of the Interior
2014-2016 Member, Tax System Development Review Committee, Ministry of Economy and Finance
2014 Member, Advisory Committee on Normalization of Underground Economy, National Tax Service
2014 Professor, 17th Tax Law Training Course, Tax Training Institute, Seoul Bar Association
2013-2017 Member, Examination Committee on Established Rules for National Taxes of Tax and Customs Office of Ministry of Economy and Finance
2013-2017 Member, Committee for Evaluation of Pro Bono Activities, Korean Bar Association
2013-2015 Auditor, International Fiscal Association Korea
2013-2014 Chairman, Tax Law Subcommittee, Korea Tax Research Forum
2013 Professor, 16th Tax Law Training Course, Tax Training Institute, Seoul Bar Association
2012-2014 Member, Administrative Appeal Commission, National Assembly Secretariat
2011-2012 Accounting, Association of Korean Residents in Leman (Geneva), Switzerland
2010-至今 Member, Judging Committee for Registration of Lawyer's Legal Speciality (Tax Law), Korean Bar Association
2009-2013 Director, International Fiscal Association Korea
2009-2010 Professor, 12th Tax Law Training Course, Seoul Bar Association
2008-2010 Member, International Tax Laws and Regulations Reformation Committee, National Tax Service
2008-2010 Editorial Member, Bulletin Editing Committee, Seoul Bar Association
2008-2009 Professor, 11th Tax Law Training Course, Seoul Bar Association
2008-2009 Legal Counsel, Korea Educational Broadcasting System
2008-2009 Member, 4th Deliberation Committee, Publication Ethics Commission
2007-至今 Director, Seokjung Future Foundation
2007-2010 Investment Promotion Advisory Member, Jeju Free International City Development Center
2007-2010 Member, Committee for Evaluation of Pro Bono Activities, Seoul Bar Association
2007-2010 Legal Counsel, Seoul Federation of Teachers Associations
2007-2010 Memebr, Real Estate Price Stabilization Deliberation Committee, Ministry of Economy and Finance
2007-2008 Member, Tax Law Review Committee, Office of Tax Customs, Ministry of Economy and Finance
2006-至今 Adjunct Professor, National Tax Officers Training Institute of National Tax Service
2006-2012 Auditor, Tax Law Association
2006-2010 Legal Adviser for Tax Law, National Tax Service
2006-2009 Member, Will Consulting Committee, The Beautiful Foundation
2006-2007 Member, Nonlisted Stock Evaluation and Review Committee, NTS Seoul Regional Office
2006-2007 Member, Nonlisted Stock Evaluation and Review Committee, NTS Daejeon Regional Office
2006 Examination Maker for the Primary Judicial Examination, Ministry of Justice
2005-至今 Member, Society for the Research of Special Litigation Service, Supreme Court of Korea
2004-至今 Member, Dissertation Review Committee, Seoul Tax Law Review, Tax Law Association
2004-2007 Member, Nonlisted Stock Evaluation and Review Committee, National Tax Service
2004-2006 Chairman, Tax Law Subcommittee, Korea Tax Research Forum
2004-2006 Research Director, Korea Tax Law Association
2003-2008 Legal Counsel, Tax and Customs Office, Ministry of Economy and Finance
2003 Visiting Member of Research Committee, Korea Institute of Public Finance
2001-2002 Legal Counsel, NTS Jungbu Regional Office

主要业务案例

Represented Seoul Housing & Communities Corporation in a litigation for recocation of imposition of value added tax (2020)
Represented Korea Railroad in a litigation in relation to Yongsan development project, involving corporate tax amounting to KRW 1trillion (2020)
Represented Korean Broadcasting System in a request for the review on appropriateness of tax imposition (2020)
Represented Hyundai Motor Company in a rectification claim regarding the purchase tax amount of value added tax (2020)
Represented Hyundai Motor Company in a rectification claim regarding the local corporate income tax (2020)
Represented Seoul Housing & Communities Corporation in a litigation for recocation of imposition of value added tax (2020)
Represented Kia Motors Corp. in a rectification claim regarding the local corporate income tax (2020)
Advised Celltrion in a litigation in connection with gift tax
Advised Hankook Tire on rules on investment in kind
Advised Shinhan Financial Group on tax audits
Represented GS Caltex in a litigation for revocation of imposition of corporate tax
Represented SK Telecom in a litigation for revocation of imposition of corporate tax
Represented CJ Logistics in a litigation for revocation of imposition of corporate tax
Represented Shinhan Bank in a litigation for revocation of imposition of gross real estate tax
Represented Daekyo in a tax audit and provided relevant legal advice
Represented and advised LG Display in tax audits
Represented and advised NICE Information Service in tax audits
Advised POSCO on tax audits
Represented Korea Railroad in a litigation in relation to Yongsan development project, involving corporate tax amounting to KRW 1trillion (2020)
Represented Korean Broadcasting System in a request for the review on appropriateness of tax imposition (2020)
Represented Hyundai Motor Company in a rectification claim regarding the purchase tax amount of value added tax (2020)
Represented Hyundai Motor Company in a rectification claim regarding the local corporate income tax (2020)

学历

2003 California Western School of Law (M.C.L.)
1994 Judicial Research and Training Institute, Supreme Court of Korea
1992 Seoul National University (LL.M.)
1989 Seoul National University (LL.B.)

主要社会活动

著作
Tax Cases Explained by Cheol Hyung Yu VII (Sejungilbo, 2023)
Review on the 2022 Supreme Court’s Decisions Related to the Framework Act on National Taxes, The Korean Journal of Taxation Vol. 8 No. 2, pp. 5-47 (Korean Society of Tax Law, 2023)
Current Trend of Tax Court Rulings on Public Interest Corporations, Study of Taxation System of Public Interest Corporations, The Annual Public Interest Law Paper Series Vol. 8 (Kyungin Publishing, 2022)
Tax Cases Explained by Cheol Hyung Yu VI (Sejungilbo, 2022)
Plan for Improvement of Taxation System Regarding Stock Holdings by the Corporate Public Interest Foundation, Study on Public Interest Foundation Legal System, The Annual Public Interest Law Paper Series Vol. 7 (Kyungin Publishing, 2021)
Tax Cases Explained by Cheol Hyung Yu V (Sejungilbo, 2021)
A Study on the Scope of ‘Judgment’ Eligible for Request for Correction Based on Subsequent Events, Seoul Tax Law Review Vol. 26 No. 3, pp. 147-184 (Tax Law Association, 2020)
Practical Guide to Investment in North Korea (Co-author, Do & Book, 2020)
Tax Cases Explained by Cheol Hyung Yu IV (Sejungilbo, 2020)
Review of Cases in 2019 Involving the Local Tax, Tax Study Vol. 20 No. 1, pp. 7-40 (Korea Tax Research Forum, 2020)
Tax Cases Explained by Cheol Hyung Yu III (Sejungilbo, 2019)
Explanatory Notes on Termination of Contract and Rectification Claims regarding Acquisition Tax, The Taxation Monthly Vol. 370 (Jose-Tongram. Corp., 2019)
Review of Cases in 2018 Involving the Local Tax, Tax Study Vol. 19 No. 1, pp. 7-54 (Korea Tax Research Forum, 2019)
Research on Gift Taxation of Repeated Name Trusts Established in the Name of Same Trustee, Seoul Tax Law Review Vol. 25 No. 2, pp. 93-134 (Tax Law Association, 2019)
Tax Cases Explained by Cheol Hyung Yu II (Sejungilbo, 2018)
A Study on the Substance Over Form Principleunder Tax Treaties, Journal of IFA Korea Vol. 34 No. 2, pp. 1-31 (International Fiscal Association Korea, 2018)
A Study on the Retroactive Applicability of Regulation determining Title Transfer based on Share Change Circumstances Registry, Seoul Tax Law Review Vol. 24 No. 3, pp. 313-350 (Tax Law Association, 2018)
Review of Cases in 2017 Involving the Inheritance and Gift Tax Act, Korean Journal of Taxation Research Vol. 35 No. 4, pp. 41-83 (Korean Academic Society of Taxation, 2018)
Tax Cases Explained by Cheol Hyung Yu I (Sejungilbo, 2017)
Review of Cases in 2016 Involving the Local Tax, Local Tax Review Vol. 4 No. 1, pp. 75-112 (Korea Local Tax Association, 2017)
Whether Moving into Seoul Metropolitan City from a Large City Is Subject to Double Taxation of Acquisition Tax, Local Tax Review Vol. 3 No. 1 (Korea Local Tax Association, 2016)
Interpretation of individual example provisions under Inheritance and Gift Tax Act, Tax Study Vol. 16 No. 3, pp. 145-192 (Korea Tax Research Forum, 2016)
Patents Unregistered in Korea and Korean Source Royalty Income-Focus on Relevant Supreme Court decisions, Journal of IFA Korea Vol. 32 No. 3, pp. 119-163 (International Fiscal Association Korea, 2016)
Legal Characteristics of the Provisions on Collection over Transactions under the Value-Added Tax Act, Selected Tax Precedents 2, pp. 507-513 (Pakyoungsa, 2016)
Assignment of Buildings and Supply of Goods under the Value-Added Tax Act, Selected Tax Precedents 2, pp. 522-527 (Pakyoungsa, 2016)
Analogical Application of the Provisions of Article 61 of the Old Enforcement Decree of the Value-Added Tax Act upon Cross-Ownership of Taxable and Non-taxable Businesses, Selected Tax Precedents 2, pp. 514-521 (Pakyoungsa, 2016)
Supply of Advertising Services for Foreign Advertisers and the Tax Rate of Zero Percent, Selected Tax Precedents 2, pp. 528-534 (Pakyoungsa, 2016)
Study on Taxability and Issues of Illegal Income, Tax and Accounting Review Vol. 4 No.1, pp. 47-100 (Co-author, 2015)
Key International Tax Issues related to Acquisition of Domestic Companies by Foreign Investors, BFL No. 73, pp. 71-90 (Co-author, Seoul National University Center for Financial Law, 2015)
Fair Market Value as the Standard for Evaluation of Transfers at Excessively High Prices and the Priority Principle of Income Taxation - Commentary on the Supreme Court Decision 2012du3200, June 14, 2012, Tax Study Vol. 14 No. 1, pp. 93-122 (Korea Tax Research Forum, 2014)
Measures to improve the legal and institutional standards based on the experience in the management of Gaesung Industrial Complex (Co-author, Ministry of Unification, 2013)
Gift Tax Implications on Shareholders of Profitable Corporations to Receive Gifts, Seoul Tax Law Review Vol. 18 No. 3, pp. 400-435 (Tax Law Association, 2012)
Claim for Indemnity of Withholding Agents in Respect of Deemed Bonus for Representatives, Special Law Study 9, pp. 309-334 (Jurisdiction Development Foundation, 2011)
Actual Condition of and Method to Improve the Gift Tax System under the Comprehensive Taxation Principle, Lawyer Vol. 39, pp. 254-295 (Seoul Bar Association, 2009)
Income Deemed as Bonuses of the Representative and the Extent of Claim for Indemnity by the Withholding Agent - Supreme Court 2006DA49789 decided on 2008.9.18(unanimousdecision), Seoul Tax Law Review Vol. 15 No. 2, pp. 114-153 (Tax Law Association, 2009)
Review of 2007 Corporate Income Tax Law Cases, Seoul Tax Law Review Vol. 14 No. 1, pp. 373-425 (Tax Law Association, 2008)
Tax assessment method applicable to the inheritance or donation of land where the publicly announced land price for the relevant year is not announced - Commentary on Supreme Court's Judgment 2001Du10677 dated September 2, 2003, Tax Study Vol. 8 No. 2, pp. 190-217 (Korea Tax Research Forum, 2008)
Review of 2006 Inheritance Tax and Gift Tax Act Cases, Seoul Tax Law Review Vol. 13 No. 1, pp. 419-449 (Tax Law Association, 2007)
Review of 2005 Tax-related Constitutional Cases, Seoul Tax Law Review Vol. 12 No. 1, pp. 317-361 (Tax Law Association, 2006)
Explanatory Notes on Laws, Regulations and Systems Governing Gaesung Industrial District (Co-author, Ministry of Unification, 2005)
Review of 2004 Value-Added Tax Act Cases, Seoul Tax Law Review Vol. 11 No. 1, pp. 445-486 (Tax Law Association, 2005)
Input Tax Deduction on Auctions, Selected Tax Precedents, pp. 499-507 (Pakyoungsa, 2005)
Retroactive Tax Bills and Untruthful Tax Bills, Selected Tax Precedents, pp. 513-519 (Parkyoungsa, 2005)
Basic Research for the Legal Review and Institutionalization of Restructuring Plans for Private Universities (Co-author, Ministry of Education & Human Resources Development, 2005)
Research on Issues Relating to Value Added Taxes in Case of Auction (Korea Institute of Public Finance, 2003)
Retrospect of Precedent Cases in 2001 Relating to Inheritance Tax and Gift Tax Act, Seoul Tax Law Review Vol. 8 No. 1, pp. 283-305 (Tax Law Association, July of 2002)
Constitutionality of the Proviso in Article 35 Paragraph 1 Subparagraph 3 of the Basic National Tax Act, Vol. 164 (Jose-Tongram. Corp., 2002)
Review of 2000 Cases Involving the Inheritance and Gift Tax, Seoul Tax Law Review Vol. 7 (Tax Law Association, 2001)
Scope of Joint & Several Liability of Joint Heirs to Pay Inheritance Tax, Vol. 24 (National Tax Service, 2001)
Priority between Gift Tax and Security Interests, Seoul Tax Law Review Vol. 5, pp. 304-318 (Tax Law Association, 1999)
Review of 1994 Cases Involving the Value Added Tax, Seoul Tax Law Review Vol. 1, pp. 357-360 (Tax Law Association, 1995)
A Study of the Land Excess Profits Tax Law (Master's Thesis, Seoul National University, 1992)
活动
National Tour Lecture of Local Tax Law, Ministry of the Interior (2016-2017)
Lecturer, Yonsei Universtiy Grauate School of Law (2016)
Lecture on Tax Law, Judicial Research and Training Institute (2014)
Lecturer, Korea University Graduate School Department of Law (2013-2014)
Lecture on Tax Law, Business Law Manager Course, LAWnB (2003-2009)
奖项
Chambers Asia-Pacific - Leading Lawyer (2018-2024)
Achievement Award (Seoul Bar Association, 2021)
Presidential Citation (2019)
Order of Civil Merit (Seongnyu Medal, 2015)
Citation (Minister of the Interior, 2014)
Citation (Chairman of Seoul Bar Association, 2010)
Citation (Commissioner of National Tax Service, 2010, 2020)
Prime Minister's Citation (2006)

资格

1994 Korea
1994 Certified Tax Consultant (Korea)
1994 Patent Attorney (Korea)

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