The Appellant (a car manufacturer) was the administrator of various defined benefit pension plans for its employees. It directed the trustee of the plans to pay the fees of third party portfolio advisors out of the trust assets.
After finding that the Appellant was eligible for input tax credits for the GST that was charged on the fees, Campbell J went on to indicate that the portfolio advisory services did not qualify as financial services given that the portfolio advisors did not actually trade in the securities held by the plans.