Crown-owned entities not eligible for the RDTI

The following crown-owned entities, including associates and entities controlled by them, are not eligible for the RDTI:

  • Crown Research Institutes (CRIs)
  • Tertiary Education Organisations (TEOs) including foreign-owned TEOs
  • District Health Boards (DHBs)
  • Callaghan Innovation.


What’s an associate?

Entities are considered to be “associates” when they have a close relationship and common interest.


What does control mean?

The word control is not defined in tax law but could include:

  • ownership of 50% or more of shares or voting interests in another entity
  • control of appointments to an entity’s controlling board.

Control transfers through entities - for example, if ‘A Co’ controls ‘B Co’, and ‘B Co’ controls ‘C Co’, then ‘A Co’ is also considered to control ‘C Co’.