The two bakery plants of the appellant in Toronto were staffed in significant part by temporary workers (“TWs”), who were sourced from third parties (the “Agencies”), which solicited for the TWs and directed them to the appellant. The appellant kept detailed records as to the hours worked by the TWs, which it provided to the Agencies for billing purposes, received invoices from the Agencies for the amounts identified in the invoices, and paid the Agencies therefor (including for HST) once it reconciled the amounts with its records.