Newly-released information GST/HST reporting requirements for pension plan employers are not onerous

The Government's loss in the General Motors case caused it to enact s. 172.1, which requires employers to remit imputed GST or HST on their expenditures in administering employee pension plans.  CRA has now released the required information reporting that the employer is required to provide to the pension plan (which is entitled generally to a rebate of 33% of the imputed tax).

Generally, it's not very onerous (and there doesn't appear to be a prescribed form).  Typically, in addition to minor administrative particulars, the employer is only required to specify the aggregate federal and (if applicable) provincial imputed tax for the year - although there's a vague statement to the effect that where there were actual supplies to the pension fund, "the employer must provide sufficient information to enable the pension entity to claim an ITC... ."

Neal Armstrong.  Summary of  Notice No. 280 "Section 172.1 Information Requirements" January 2013 under ETA - s. 172.1(8).