A GP can claim ITCs for incestuous HST (on charges made to it by the limited partnership)

S. 272.1(2) generally permits a partner to claim an input tax credit for HST that it pays in acquiring property or services on its own account (rather than as agent for the partnership) for use or supply in commercial activities of the partnership (provided that it claims the ITC before it is reimbursed by the partnership).  If you think this provision applies only to third-party charges, you are wrong.  CRA has confirmed that it can also apply to internal charges, i.e., to HST charged by the partnership itself to its GP.

The particular situation was that a limited partnership employed executives whose salaries were charged through to the GP on the basis that it was the responsibility of the GP rather than the partnership itself to manage the partnership business.

Neal Armstrong.  Summary of 26 June 2013 Opinion Case No. 144410 under ETA, s. 272.1(2).