A Co is entitled to full ITCs for the GST/HST on fees paid by it to third parties in respect of its pension plan for employees including charges for administration, actuarial and investment consulting, as being the one liable to pay the fees. However:
where expenses incurred by [A Co] have been paid from the Pension Fund, we would consider [A Co] to have made a taxable supply of services for consideration equal to the invoice amounts. [A Co] would therefore be required to account for the GST/HST calculated on these amounts under sections 221, 225 and 228.