CRA finds that an employer generally is entitled to claim input tax credits for GST/HST charged to it by pension plan consultants

Although the concept of an on-sale of goods is obvious, that of an on-supply of services is more intractable.  Nonetheless, there is a tendency to find a double supply where there is a double payment (unless agency is established).

For example, CRA considers that where a pension plan employer is charged for actuarial services but is entitled to be reimbursed out of the pension funds, the employer has received a supply of the actuarial services and is entitled to claim an input tax credit for the HST charged to it (assuming it is engaged in commercial activity) – but must collect HST on the reimbursement charge made to the pension plan. See also Caithkin.

Neal Armstrong. Summary of 26 June 2014 Ruling 157148 under ETA, s. 123(1) – recipient.