Canada v. General Motors of Canada Limited, [2009] GSTC 64, 2009 FCA 114 -- summary under Subsection 169(1)

The registrant ("GMCL") was entitled to input tax credits for the GST on fees it paid to third-party pension fund managers given that it was liable under agreements with them to pay for their services (and even though it would either be reimbursed by the pension funds or the pension funds would pay the funds directly) and given that it acquired their services as an integral part of the overall compensation package which it provided to its employees in that without a profitable pension plan, its capacity to successively compete in the marketplace would have been diminished.