United States securities and exchange commission logo

                              October 28, 2022

       Shinyoung Park
       Chief Financial Officer
       Magnachip Semiconductor Corporation
       c/o MagnaChip Semiconductor S.A.
       1, Allee Scheffer, L-2520
       Luxembourg, Grand Duchy of Luxembourg

                                                        Re: Magnachip
Semiconductor Corporation
                                                            Form 10-K for the
Year Ended December 31, 2021
                                                            Filed February 23,
                                                            File No. 001-34791

       Dear Shinyoung Park:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Year Ended December 31, 2021


   1.                                                   Please tell us and
revise to disclose the parties to which you refer to in the Form 10-K. In
                                                        this regard, we note
that you refer to a parent entity in terms of a terminated merger on
                                                        page 45 but also refer
to a parent entity in the U.S. that accounts for part of your tax
                                                        expense on page 70.
Your response and revised disclosure should name the parent entity
                                                        that had to pay
termination fees for the failed merger and clarify whether you have any
                                                        further relationship
with this entity subsequent to such attempted merger.
       Explanation and Reconciliation of Non-U.S. GAAP Measures, page 48

   2.                                                   We refer to adjustment
(i) on page 54. Please tell us and revise to further explain the
                                                        nature of the material
adjustment of $43.9 million for 2020 that eliminates the impact of
                                                        the difference between
GAAP and cash tax expense.
 Shinyoung Park
Magnachip Semiconductor Corporation
October 28, 2022
Page 2

       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Heather Clark at 202-551-3624 or Kevin Woody at
202-551-3629 with
any questions.

FirstName LastNameShinyoung Park                          Sincerely,
Comapany NameMagnachip Semiconductor Corporation
                                                          Division of
Corporation Finance
October 28, 2022 Page 2                                   Office of
FirstName LastName