Pernille Jensen CA: An international tax career
ICAS speaks with Pernille Jensen CA, Director of Global Taxation at Celestica, about transfer pricing, manufacturing and the challenges of working with international tax laws.
Where did you start your career?
I started my career in corporate tax with KPMG in London out of school in their three-year program. I was interested in law and accounting because I like to argue my case and solve problems – tax is a good fit for that. I slowly moved my focus to international tax and transfer pricing.
I worked in the London area for three years post qualifying in 2007. There was a position for a six-month secondment in Toronto where KPMG’s international head office for global tax is located.
Working with global tax partners, I gained insight from an operations standpoint on how international organizations operate on a global level. After that six months, I decided to stay in Toronto, so I reached out to the head of transfer pricing at KPMG Canada and the other transfer pricing partners - they liked me and offered me a permanent job.
In 2014, I wanted to see what’s on the other side of the fence. Now, I manage the international tax affairs for Celestica - a Canadian electronics manufacturer.
What are your responsibilities at Celestica?
We’re a manufacturing company and produce electronics for name brands – companies will outsource the manufacturing process to us. We operate in at least 20 countries, and 80% of our revenue is in Asia.
We have to find the most cost-effective place to manufacture or find solutions to where our customers require us to manufacture (often the same) and therefore often move operations from country to country, which is a challenge.
Some countries will provide a tax incentive for opening a factory and employing a certain number of local employees. You don’t pay tax for a predetermined number of years provided these conditions are met.
My job is to make sure we do everything by the law and in the most tax-efficient manner.
Once a jurisdiction becomes tax-paying, it usually presents a number of challenges for the company, such as tough tax audits and difficulties exiting if the customer requires us to move operations elsewhere.
If the business has a new customer that wants to manufacture in say Brazil or Peru, while we may have a factory there, I’ll advise on whether using that country is a good idea. We have to figure out how to operate in that jurisdiction in the most tax effective way – essentially, we manage a network of manufacturing, holding and finance companies – it’s a puzzle where you don’t want cash stuck somewhere you can’t repatriate.
My job is to make sure we do everything by the law and in the most tax-efficient manner. This can include working with a legal team to set up contracts to make sure we don’t get caught with any odd tax provisions and pay tax only when we need to.
My job isn’t confined to just tax law issues. To do my job effectively, I need to know the entire supply chain, including what we’re going to do with a product and how it’s getting to its destination. Transfer pricing is more integrated with the business and supply chain rather than just tax law.
What are some of the challenges when working in different countries for tax law?
Many countries are introducing transfer pricing to generate additional revenue. Transfer pricing isn’t an exact science though. Since very little tax law is written on transfer pricing, much is up to interpretation.
Asian countries that look to introduce legislation similar to what we do in the western world try to follow OECD principles, but these countries don’t have the resources (yet) to deal with transfer pricing on a fair tax scale, and there’s little negotiation. I find there are many audits in Asia because transfer pricing is relatively new to the region.
The international tax landscape is changing. Overall, countries have pressure to align their tax rates, but with the regulations some countries are introducing, it has become harder to move around the world.
Companies now have an opportunity to tidy their structures and look at their financing, so they can comply with different regulations and figure out if it’s worth it to have holding companies in different jurisdictions.
What challenges do you see in modern manufacturing and markets?
Traditional electronics manufacturing is becoming more competitive. Some traditional equipment manufacturers are expanding into their own R&D as they try to innovate or diversify into more niche manufacturing.
To survive, you have to look beyond original manufacturing and be the fastest and most cost-efficient. Contracts are given case by case - if you don’t do a good job, your competitor will get it next time.
What advice do you have for new members and just-qualified CAs?
Never turn down a new challenge, even if you don’t think it’s a good idea. Today, you have to be well-rounded - you need many skills and to be able to work with different stakeholders.
Since multinationals are combining tax and treasury departments, you have to understand tax law and treasury and be able to solve problems like how to get money out of a country without breaking laws or how to finance a recent acquisition in a third country.
If there’s a special opportunity, I would always say yes, so I can work with different departments. You build your network and become the point person for that department, which can expand your job responsibilities and goodwill within the organization.
About the author
Andrea Murad is a New York–based writer. Having worked on both Wall Street and Main Street, she now pursues her passion for words. She covers business and finance, and her work can be found on BBC Capital, Consumers Digest, Entrepreneur.com, FOXBusiness.com, Global Finance and InstitutionalInvestor.com.