CRA may characterize investment management services provided to a pension plan as supplied to the employer, and on-supplied to the plan

A service which in reality is provided by A to C may be viewed by CRA as a double supply made by A to B, and by B to C, if it is B who retained the services of A. For example, where an employer retains an investment manager for the company pension plan, and the pension plan pays the manager directly, CRA considers there to be a double supply of a service from the manager to the employer, and by the employer to the plan, so that the employer generally may claim an ITC for the HST payable to the manager, and is required to collect a corresponding HST amount from the plan. (This is broadly consistent with Caithkin, respecting a double supply of foster care services.)

Neal Armstrong. Summary of B-032 “Expenses Related to Pension Plans” 17 November 2015 under ETA s. 123(1) - recipient.