Tax Practice Group Tax Practice Group

TAX PRACTICE GROUP TAX PRACTICE GROUP

YOON & YANG Yoon & Yang LLC, which was established in 2003 through the merger of Yoon & Partners and Roh LLC & Yang, has provided the optimized legal service to clients by maintaining perfect balance between consulting and litigation services.

Yoon & Yang LLC has systematically streamlined its expertise and know-how in every area of corporate counseling and litigation for the purpose of providing a more specialized legal service. The firm’s professionals are grouped into specialized teams according to practice area centering on the expertise and know-how of the experts in their respective fields. The close cooperation between the teams enables the firm to provide optimized one-stop legal services.

Yoon & Yang LLC practices law with the mindset of viewing our services from the perspective of clients based on the staunch belief that it is only possible to provide the highest quality legal services when the requisite care and attention are paid to clients and the trust of clients has been earned.

Yoon & Yang LLC aims at providing the highest quality legal services, while observing ethical principles and valuing democratic relationships. The firm strives to grow into a world-class law firm based in Korea to provide a one-stop total legal service and develop together with our clients. TAX Yoon & Yang Tax Practice Group is comprised of a team of leading attorneys, certified public accoun- PRACTICE tants, and certified public tax accountants with depth of knowledge and decades of experiences who GROUP can provide the highest quality services for diverse tax issues. By organizing a team that is custom- ized to the needs of our clients, we are able to offer a systematic approach to our services, and the team’s professionalism, achievement, and competence are well recognized in the market.

Yoon & Yang Tax Practice Group is headed by tax practitioners who are most highly regarded in the field. The team includes many former judges with tax expertise at different levels of courts including the Supreme Court, former Commissioner of the National Tax Service, former Commissioner of Re- gional Tax Offices, former Commissioner of the Seoul Main Customs Office, and other former high- ranking officials at the National Tax Service in addition to many attorneys and other tax practitioners with decades of experience.

Yoon & Yang Tax Practice Group offers creative, practical, and comprehensive tax management services in tax advisory services, tax audit defense support, tax appeal, tax litigation, corporate management consulting and strategic planning. The Group represents clients in administrative proceedings before the National Tax Services, the Board of Audit and Inspection of Korea, and the Tax Tribunals in addition to administrative proceedings. The Group also handles high-stakes tax litigations and disputes. In addition, the Group advises clients in the most effective way in creating innovative and efficient solutions to complex tax issues arising from various transactions and business operations including M&A transactions, investment, global tax planning and transfer pricing that are vital to many domestic and multinational company’s operations in/outside Korea. Furthermore, the Group is equipped with talented customs professionals who offer wealth of expertise and experience in customs matters, foreign exchange, and FTA origin verification. PRACTICE TAX LITIGATION AND DISPUTES AREAS OF • Administrative tax appeal procedures (filing of review of tax imposition, administrative appeals, and TAX GROUP appeal to the Tax Tribunal) • Administrative tax litigation • Civil tax litigation (claim for tax refund from improper tax assessment) and criminal tax litigation • Constitutional tax litigation

TAX ADVISORY • Tax advice on general corporate matters • Tax advice on restructurings including merger and division • Strategic tax planning for new investment and business • Tax advice on trusts • Tax planning advice including inheritance, gift, and transfer • Tax advice on family business succession • Advice on tax legislation and amendment, authoritative interpretation

INTERNATIONAL TAXATION • International tax advice regarding implementation of BEPS Project • Transfer pricing advice (planning and documentation) • Assistance with Advance Pricing Arrangement (APA) and Mutual Agreement Procedure (MAP) • Tax advice on Korean enterprises’ outbound investment and M&A • Tax advice on foreign enterprises’ inbound investment

TAX AUDIT • Preliminary risk diagnosis before tax audit • Tax audit defense on corporate tax, value added tax, individual income tax, and local tax • Tax audit defense on capital gain tax, inheritance tax, and gift tax • Tax audit defense on on-site investigation of value added tax and special audit of tax evasion and tax crimes, offshore tax evasion, and sources of operation funds

CORPORATE OPERATION AND TAX COMPLIANCE SUPPORT • Assistance with tax compliance services, tax advisory, and tax agency services regarding establishment, corporate operation, closing account, and liquidation of foreign invested corporation, foreign corporation’s branch, and liaison office • Tax advisory and tax agency services for non-resident and foreign expatriate in Korea • Support for application of compliant tax reporting system

CUSTOMS • Corporate customs audit (corporate, AEO, and planning audit) • Assistance with Advance Customs Valuation Agreement (ACVA) • HS Code Classification assessment for exported or imported goods • FTA origin verification (written inspection and on-site inspection) • Administrative customs appeal procedures (filing of review of tax imposition, administrative appeals, and appeal to the Tax Tribunal) and administrative customs litigation • Customs violation investigation (customs criminal and foreign currency criminal) and foreign currency inspection TAX LITIGATION AND DISPUTES KEY Successfully represented clients in various levels of tax controversies in which the tax authorities chal- REPRESENTATIVE lenged the clients’ tax position based on: AND • Whether certain type of income should be treated as effectively connected (or substantially related) income subject to withholding tax. ADVISORY • Whether a foreign invested company’s place of business in Korea may be deemed as permanent establish- MATTERS OF ment. TAX GROUP • Whether a royalty payment for a patent license is domestic source income subject to withholding tax. • Whether a gift tax was triggered from a corporate restructuring process under the comprehensive taxation principle, which allows taxation on all items including those not specifically enumerated under the Inheri- tance Tax and Gift Act. • Whether certain item was subject to value-added tax, and whether the input tax amount for value-added tax purposes was correctly calculated on the basis of proportional distribution among taxable and tax-free business. • A number of criminal cases concerning violations of the Act on the Aggravated Punishment, etc. of Specific Crimes (Tax) and Punishment of Tax Evaders Act.

TAX ADVISORY SERVICE Advised clients on various tax matters arising from: • The share transfer of a non-listed company, establishment of a foreign subsidiary, and other related transactions. • Transfer of a parent company’s shares and capital increase followed by establishment of a subsidiary and transfer of its business. • Formulation of tax strategies for foreigners and their representation. • Establishment of an SPC by foreigners in Korea. • Increased equity of an oligopolistic shareholder due to capital increase. • Foreign company’s purchase of real estate in Korea. • Corporate restructuring.

INTERNATIONAL TAXATION Advised clients on various international tax matters arising from: • Transfer pricing documentation (Master File and Local File) in relation to the BEPS recommendations. • in-depth review of tax effects on establishment of an overseas holding company in connection with overseas expansion. • Withholding tax on interest and gift income in connection with issuance of offshore bonds. • Permanent establishment issues relating to the Korean offices of multinational enterprises. • Whether a foreign enterprise’s acquisition of new shares constitutes a transaction involving a third party within the meaning of the Law for the Coordination of International Tax Affairs. • Transfer pricing methodology of computing the arm’s length price. • Korean enterprise’s services provided to a foreign subsidiary and foreign enterprise’s services provided to a Korean subsidiary. • Transfer of shares of a Korean enterprise owned by a foreign enterprise to another Korean enterprise. • Transfer of shares of a Korean enterprise owned by a foreign private equity fund.

TAX AUDIT • Represented corporations, high-net-worth individuals, and large businesses in tax audit and special audit of tax evasion and tax crimes. • Represented a client in a tax audit regarding construction of a golf course and stock conversion of a convertible bond. • Represented clients in tax audits regarding sales revenue omissions and bank account investigation. • Represented a client in a tax audit regarding receipt of a large sum of properties, fund source, slush fund formation, and borrowed-name bank account. • Represented a client in a tax audit regarding capital gain tax, inheritance tax, and gift tax matters. CORPORATE OPERATION AND TAX COMPLIANCE SUPPORT • Provided tax advisory services for establishment and operation of domestic corporations, foreign invested corporations, foreign corporations’ liaison offices and branches. • Assisted with closing account of foreign invested corporations and foreign corporations’ branches. • Prepared and filed corporate tax returns for domestic and foreign invested corporations. • Prepared and filed value added tax return for domestic and foreign invested corporations. Provided tax audit defense support for on-site investigation of value added tax. • Provided tax agency and advisory services regarding capital gain from non-residents’ transfer of shares. • Provided tax agency and advisory services for foreign expatriates in Korea.

CUSTOMS • Represented a multinational company in connection with medical equipment in the advance classification ruling and transfer pricing related customs appeal. • Represented a client in a customs audit regarding an allegation of violations of the Customs Act and the Trademark Act. • Performed origin verification defense on the gold bullion imported under the preferential tariff of the Korea-EFTA FTA. • Advised in connection with the origin investigation of orange and footwear imported under the preferential tariff treatment of the Korea-US FTA. • Represented a client in a customs audit regarding an allegation of violation of the Foreign Currency Transaction Act and overseas flight of assets in connection with processing export. • Represented a client in a customs audit regarding an allegation of tariff evasion. • Advised large Korean oil companies on additional tariff levied on crude oil.

Yoon & Yang LLC Tax Practice Group

Seung Soon Lim Oh-Young Jeon Wankyu Jeon Managing Partner Attorney Partner Attorney Partner Attorney [email protected] [email protected] [email protected] Tel. +82-2-6003-7124 Tel. +82-2-6003-7134 Tel. +82-2-6003-7121

18th, 19th, 22nd, 23rd, 34th Fl., ASEM TOWER 517 Yeongdong-daero, Gangnam-Gu, Seoul 06164, Korea Tel: +82-2-6003-7000 Web-site: www.yoonyang.com PROFESSIONALS OF TAX GROUP

Seung Soon Lim Seung Soon Lim, one of the most prominent tax lawyers in Korea, is leading the overall Tax Group as a managing Managing Partner Attorney partner at Yoon & Yang LLC. After completion of the 9th Judicial Research and Training Institute, he served as a judge and chief judge at various courts and retired as the Chief Judge at the Seoul Administrative Court. Mr. T: +82-2-6003-7124 Lim actively participates in the tax related areas. He served as the Commissioner of the National Tax Appeals Bureau of the National Tax Service, Commissioner of the Administrative Appeals Commission of the Prime Min- E: [email protected] ister, Commissioner of the Pre-assessment Review Committee of the National Tax Service, Tax Law Advisor of the Seoul Regional Tax Office, and Commissioner of the Review Committee for National Tax Appeal of the Ministry of the Strategy and Finance. He currently serves as the Commissioner of the Legal Interpretation Deliberation Committee of the Ministry of Government Legislation. Mr. Lim is internationally recognized as a leading corporate tax lawyer, and he was named as the “Leading Corporate Tax Lawyer” in Korea by International Who’s Who of Corporate Tax Lawyers in 2013. His most notable publication, the “Tax Law,” has been the most frequently refer- enced textbook among tax experts.

Duk mo Chung Duk Mo Chung is a managing partner at Yoon & Yang LLC. His main areas of practice are civil litigation, crimi- Partner Attorney nal law, tax law, and administrative law. After completion of the 13th Judicial Research and Training Institute, Mr. Chung served as the Presiding Judge of the Civil Department (general civil affairs and construction), Crime T: +82-2-6182-8301 Department (corruption and general crimes), and Administration Department of the Seoul High Court, Daejeon High Court, Seoul Central District Court, and Suwon District Court during his tenure as a judge for 26 years. In E: [email protected] particular, he served as the Research Judge and took charge of tax cases for 4 years as the Chief of the Tax Team.

Oh-Young Jeon Oh-Young Jeon is a partner at Yoon & Yang LLC. His main practice area is corporate litigation, especially in tax, Partner Attorney real estate, and construction areas. Based on his previous experience as a Judge in Korean courts including the Seoul Central District Court, which he joined after completion of the 17th Judicial Research and Training Institute, T: +82-2-6003-7134 Mr. Jeon, as a leader of the Tax Practice Group, provides expert advice on tax issues in connection with M&A’s, foreign investment, and various projects. Mr. Jeon specializes in defending companies facing tax authority’s in- E: [email protected] vestigations. He also actively participates in tax associations as the Director of the Tax Law Association, Commis- sioner of the Korean Bar Association’s Tax System Committee, and Tax Law Advisor of the National Tax Service.

Tae-Hwan Oh Taehwan Oh is a partner at Yoon & Yang LLC. His main practice areas are tax disputes, tax investigation, and Partner Attorney administrative appeals. His vast experience in administrative cases includes corporate tax appeals and cases regarding VAT, income tax, administrative licenses, and permissions, redevelopment and reconstruction, urban T: +82-2-6003-7597 development projects, and industrial accidents. After completion of the 28th Judicial Research and Training Insti- tute, Mr. Oh accumulated much of his experience while serving as a Judge at the Busan District Court, the Incheon E: [email protected] District Court and the Seoul Administrative Court, a specialized court for tax and administration.

Jae Woong Jeong Jae Woong Jeong is a partner at Yoon & Yang LLC. His practice concentrates on tax related disputes and ad- Partner Attorney vice. He also has worked extensively on cases regarding employment/labor, general administrative matters, land expropriation, real estate and construction, and general civil/criminal cases. Mr. Jeong has successfully dealt T: +82-2-6003-7049 with a large number of tax related litigations and advisory matters regarding various types of tax areas including corporate tax, VAT, income tax, inheritance/gift tax, and local tax. He also served as an external commissioner for E: [email protected] tax offices in Seoul including the Gangnam District Tax Office and Seodaemun District Tax Office. After completion of the 31st Judicial Research and Training Institute, he worked as a researcher at Saarland University in Germany and served as the Commissioner of the Seodaemun District Tax Office’s Review Committee for National Tax and Gangnam District Tax Office’s Committee for Protection of Rights and Interests of Taxpayers.

Wankyu Jeon Wankyu Jeon is a partner at Yoon & Yang LLC. His primary practice area includes advisory and litigation services Partner Attorney related to a full range of tax related matters including corporate tax, VAT, local tax, and especially international tax. Mr. Jeon has also performed advisory and litigation practices on general administration matters including T: +82-2-6003-7121 wind power projects and land expropriation. After completion of the 31st Judicial Research and Training Institute, he majored in accounting at Korea University Graduate School of Business Administration and acquired the certi- E: [email protected] fied tax accountant license. Mr. Jeon also received the LL.M. degree from Southern Methodist University School of Law.

Yong Taek Kim Yong Taek Kim is a partner at Yoon & Yang LLC. His main practice area is tax litigation and disputes, and he is re- Partner Attorney sponsible for various cases relating to administrative dispositions as well as general civil/criminal cases. Mr. Kim successfully represented clients in tax litigation, which include the case on VAT imposed on a large-scale gold T: +82-2-6003-7076 bullion business, the case on VAT relating to operation of railway, the case on gift tax according to a comprehensive gift tax regime, the case on VAT and local tax regarding trust business. After completion of the 36th Judicial E: [email protected] Research and Training Institute, he received the LL.M. degree from Southern Methodist University School of Law and served as a member of the Taxpayers Advocate Committee of the Seodaemun District Tax office. Duk Joong Kim Duk Joong Kim is a senior advisor of Yoon & Yang LLC. His practice areas are the national tax system and general Senior Advisor administration. While in the public office for nearly 30 years as an official at the National Tax Service and Ministry of Finance as well as training at the New York State Government, Mr. Kim served as the Information System (Certified Tax Accountant) Development Officer and Information System Investigation Officer of the National Tax Service, Senior Civil Affairs Secretary of the Blue House, Real Estate Transaction Management Director of the National Tax Service, Taxpay- T: +82-2-6003-7146 ers Advocate Officer, Tax Resource Management Director General and Investigation Bureau 2 Director General of E: [email protected] the Seoul Regional Tax Office, and Commissioner of the Daejeon Regional Tax Office. From 2009, he served as the Director General for Planning and Coordination and Director General for Legal Tax Collection of the National Tax Service, and Commissioner of the Jungbu Regional Tax Office. Mr. Kim completed his public service as the 20th Commissioner of the National Tax Service in 2014. He received the Red Stripes Order of Service Merit in 2010. After his public service, Mr. Kim also served as an endowed-chair professor at Chung-Ang University and advisor at the International Budget Office.

Yung Suh Ki Yung Suh Ki is a senior advisor of Yoon & Yang LLC, and his main practice is to provide advice for diverse tax Senior Advisor issues. After passing the 17th High Public Service Examination, he went through various posts at several public institutions such as the Head of the Direct Tax Division of the Yeosu Tax Office, Deputy Director of the Property (Certified Tax Accountant) Tax Division of the Seoul Regional Tax Office, Secretary of Commissioner of the National Tax Service, Head of tax offices at Jeongeup, Gunsan, and Bukgwangju, Real Estate Investigation Officer of the Seoul Regional Tax Office, T: +82-2-6182-8581 Head of the Bucheon Tax Office and Guro Tax Office, Administrative Management Officer of the National Tax E: [email protected] Service, Head of the Taxation Investigation Bureau of the Gwangju Regional Tax Office and Jungbu Regional Tax Office, Head of the Investigation Bureau 3 of the Jungbu Regional Tax Office, Head of the Tax Revenue Manage- ment Bureau of the Seoul Regional Tax Office, Head of the Investigation Bureau 1 of the Seoul Regional Tax Office, Commissioner of the Gwangju Regional Tax Office, and lastly, the Head of the Corporate Taxation Bureau of the National Tax Service.

Yo Seong Kim Yo Seong Kim is the representative certified public tax accountant of Yoon & Yang Tax Services Group. From Representative Certified the beginning of his career as a 9th grade public official of national tax until the voluntary resignation as a high- ranking public official, he experienced significant assignments including the head of district tax offices, Director of Public Tax Accountant the Investigation Bureau 4 and Bureau 3 of the Seoul Regional Tax Office, and Director General of the Investigation Bureau 1 of the Daejeon Regional Tax Office during his public service of 38 years. Before his retirement, Mr. Kim T: +82-2-6182-8580 led collection of tax evasion information and investigation of large domestic and foreign companies as the General E: [email protected] of the Investigation Bureau’s Investigation Intelligence Division of the National Tax Service. Mr. Kim is recognized as one of the National Tax Service’s top tax professionals that he worked in the investigation and audit areas for more than 20 years during his service as a public official of national tax. Especially during his position at the Investigation Bureau 4 of the Seoul Regional Tax Office as a tax auditor, officer, officer in charge, and director for a total of 10 years, he processed significant tax audit cases including high-valued tax evasion cases, and also, during his duty at the Office of the Inspector General of the National Tax Service as a tax inspector and deputy director of investigation for 7 years, Mr. Kim handled tax audit cases on large companies.

Myung Soon Kwak Myung Soon Kwak is a certified tax accountant at Yoon & Yang LLC, specializing in tax audit and tax litigation and Certified Tax Accountant disputes. He graduated from the National Tax College and has handled a full range of work in the tax administration areas, including national tax collection, tax appeals, tax audit, and judgment on national tax. He has worked T: +82-2-6182-8582 at the Research Bureau of the Seoul Regional Tax Office, Corporate Tax Department of the Jungbu Regional Tax Office, and tax offices in Seoul for almost 25 years. Notably, he has vast experience in the areas of corporate E: [email protected] taxation and taxation theories and has professional knowledge in tax principles from Sungkyunkwan University, Graduate School of Business Administration, Tax LL.M.

Shin-Jong Kang Shin-Jong Kang is a certified public accountant at Yoon & Yang LLC, leading the international tax advisory prac- Certified Public Accountant tice. For nearly 24 years until 2013, he has gained diverse experience in the international tax area as a tax partner at Samil PricewaterhouseCoopers, especially focusing on the transfer pricing field in Korea. Mr. Kang worked as T: +82-2-6003-7783 a manager in the international taxation and transfer pricing team in PricewaterhouseCoopers U.S. He handles tax advisory, tax audit, tax appeal, mutual agreement procedure, and advance pricing agreement for both domestic E: [email protected] and foreign multinational enterprises including major financial institutions. Mr. Kang also received a citation from the Strategy and Finance Minister in 2010.

Woo Yong Kang Woo Yong Kang is a certified public accountant at Yoon & Yang LLC, specializing in tax advice and tax appeals. Certified Public Accountant He has dealt with various affairs in the taxation field, including tax reconciliation, tax consulting, support for tax audit, tax appeals, tax due diligence, and tax counseling on M&A. Mr. Kang has also given financial tax advice as a T: +82-2-6003-7073 certified public accountant specializing in tax at major Korean accounting firms including Samjong KPMG, Samil PricewaterhouseCoopers, and Ernst & Young Korea. E: [email protected]

Dae Ho Kim Dae Ho Kim is a certified public accountant at Yoon & Yang LLC. His main practice areas include tax appeal, tax Certified Public Accountant advisory, tax audit defense and risk diagnosis, and strategic tax planning for corporate restructurings and M&A’s. Mr. Kim has gained experience for complex tax matters from corporate tax return and tax advisory work as a T: +82-2-6003-7072 practitioner or in-charge for a number of domestic and foreign companies. He also has experienced tax issues potentially arising from domestic investment of foreign capital and foreign investment of domestic capital. Prior E: [email protected] to joining the firm, Mr. Kim served as a project in-charge of corporate tax return and tax advisory work for a number of domestic and foreign banks, insurances, and securities including Kookmin Bank at Ernst & Young Korea. Yoonweon Seo Yoonweon Seo is the representative customs attorney of Yoon & Yang Customs and Trade Practice Group. After Representative graduating from Hankuk University of Foreign Studies majoring in Public Administration in 1983, he acquired the master’s degrees at Seoul National University, Graduate School of Public Administration (MPA) and Iowa Customs Attorney State University (MBA). Mr. Seo started his career in the public sector after passing the 27th High Public Service Examination in 1983 and served as the Deputy Director at the Korean Intellectual Property Office, Head of the T: +82-2-6182-6506 Customs Border Control Training Center, Director General for the Information Management Bureau of the Korea E: [email protected] Customs Service, Director General for the Investigation and Surveillance Bureau of the Korea Customs Service, Commissioner of the Busan Main Customs Service, Commissioner of the Incheon Airport Customs Service and lastly served as the Commissioner of the Seoul Main Customs Service after 2015. He has accumulated vast experience and expertise in the fields of customs and intellectual property right for a period of more than 30 years.

Jae Wan Jeong Jae Wan Jeong is a senior advisor of Yoon & Yang Customs and Trade Practice Group. He graduated Yonsei Senior Advisor University, Graduate School of Economics (major in International Economics) and received the Ph.D. degree from Sogang University, Graduate School of Business (major in Global Trade and International Business). During his (Customs Attorney) public service for 35 years from 1981, Mr. Jeong served as the Commissioner of the Review Committee for Na- tional Tax Appeal of the Ministry of the Strategy and Finance, Judge of the Tax Tribunal, Director General of the T: +82-2-6182-6000 Clearance Bureau of the Incheon Main Customs Office, and Director of the Audit Policy Division of the Korea E: [email protected] Customs Service. He was also the Chairperson of the Korea Research Society for Customs in 2014. Mr. Jeong has published a number of books and articles in relation to the customs matters, and he currently serves as a professor at Hannam University, College of Economics and Business Administration, Department of Global Trade.

Haedong Lee Haedong Lee is a senior customs attorney at Yoon & Yang Customs and Trade Practice Group. Mr. Lee graduated Senior Customs Attorney from the National Tax College majoring in Customs (the 1st graduation class) and obtained the master’s degree at Hankuk University of Foreign Studies, Graduate School of Business Administration. During his experience of over T: +82-2-6182-6507 30 years at corporate audit and foreign exchange investigation divisions of the Korea Customs Service, Seoul Main Customs Office, and Incheon Main Customs Office, Mr. Lee handled a number of cases regarding clearance audit E: [email protected] on goods of export and import declaration including plants, raw materials, and luxurious consumption goods, transfer pricing audit on multinational companies, and investigation on foreign exchange transactions until his voluntary resignation in January 2017 as an officer in charge. He published the “Practice of Customs Valuation” in 2013, which is used as the standards for corporate audit of customs valuation field.

Sung Koo Cho Sung Koo Cho is a senior customs attorney at Yoon & Yang Customs and Trade Practice Group. Mr. Cho graduated Senior Customs Attorney from Korea National Open University majoring in Public Administration in 1998 and obtained the master’s degree at Sungkyunkwan University, College of Public Administration in 2000. He has vast experience in the corporate T: +82-2-6182-6502 audit, transfer pricing, and HS classification, and is also an expert in transfer pricing, corporate accounting, and ERP system networks. Having worked at the customs offices in charge of the HS classification and customs valu- E: [email protected] ation of such items as vehicles, oil, luxury brands, and liquors, Mr. Cho has accumulated field experience and profound understanding of customs corporate audit, customs valuation, and HS classification.

Yong Tae Kim Yong Tae Kim is a senior customs attorney at Yoon & Yang Customs and Trade Practice Group. Mr. Kim graduated Senior Customs Attorney from Sungkyunkwan University in German Language and Literature, acquired an LL.M and Ph.D of Law at the Graduate School of the University of Seoul. He served as a visiting scholar at Koln University, International Eco- T: +82-2-6182-6503 nomic Law Research Institution and Gieben University, Economic Criminal Law Research Institute in Germany. He has a professional field experience of more than 31 years in the fields of FTA origin verification, violations of the E: [email protected] Foreign Exchange Transactions Act, and the Customs Act based on his career at the Korea Customs Service and various customs offices including the Seoul Customs Office, Busan Customs Office, and Incheon Airport Customs Office.

Gi Hyeon Chang Gi Hyeon Chang is a customs attorney of Yoon & Yang Customs and Trade Practice Group. Mr. Chang graduated Customs Attorney from the National Tax College majoring in Customs (the 9th graduation class) and worked at the customs offices of Masan, Daejeon, Cheonan, Incheon Airport, and Seoul in charge of import/export customs clearance, ex-post T: +82-2-6182-6505 investigation, and examination. In particular, he was dispatched to the Foreign Criminal Affairs Department of the Seoul Central Prosecutors’ Office from September 2009 to April 2015 and was in charge of dealing with criminal E: [email protected] cases of violation of the Customs Act, the Foreign Exchange Transactions Act, the Foreign Trade Act, the Act on the Aggravated Punishment, etc. of Specific Crimes and other laws, which were forwarded or reported from the customs offices, the National Police Agency, the Financial Supervisory Service, the Korea Financial Intelligence Unit (FIU), and other authorities. He is an expert in the fields of customs and foreign currency investigation.