CRA indicates that a mooted RCA providing supplementary pension benefits must be similar to the IPP which it supplements

CRA considers a plan that provides supplementary benefits to an individual pension plan to be a salary deferral arrangement rather than a retirement compensation arrangement if the benefits provided for are unreasonable – which CRA will consider to be the case unless the terms of the supplemental plan are substantially the same as those of the IPP and the supplementary benefits merely provide the employee with a supplement for the benefits that would be provided under the IPP but for the defined benefit limit.

Neal Armstrong. Summary of 14 March 2017 External T.I. 2016-0627311E5 Tr under s. 248(1) – salary deferral arrangement.