Comparisons

Australian vs New Zealand R&D Tax Incentive for trans-Tasman companies

New Zealand's RDTI is a flat 15% tax credit on eligible R&D spend of NZ$50,000 to NZ$120 million a year (more with IRD approval), and you need IRD approval before claiming. Australia's offset adds a premium to the company tax rate, refundable under $20 million turnover. Each company claims on R&D performed in its own country.

Reviewed by George WalchFacts last verified

Australian R&D Tax Incentive and New Zealand RDTI side by side

Australian R&D Tax Incentive compared with New Zealand RDTI
FactAustralian R&D Tax IncentiveNew Zealand RDTI
RateCompany tax rate plus 18.5 percentage points (refundable), or plus 8.5 or 16.5 points (non-refundable)Flat 15% tax credit on eligible expenditure
Minimum yearly spendAt least $20,000, unless paid to a non-associate registered research service provider or as a CRC contributionNZ$50,000, or less when an approved research provider is used
Upper limitPremium on R&D expenditure up to $150 millionNZ$120 million of eligible expenditure a year, unless IRD approves a higher amount
Approval before claimingNone for ordinary claims; register within 10 months after year end; advance findings optionalGeneral approval or criteria and methodologies approval required; late general approvals refused
RefundsRefundable if aggregated turnover is under $20 million and not controlled by exempt entitiesBroader refundability rules from 2020-21, with a cap based on labour-related costs
Overseas spendNeeds a positive overseas finding, and overseas spend must be less than the related Australian spendUp to 10% of total eligible expenditure can be foreign, if it supports core R&D in New Zealand
Annual returnR&D schedule with the company return, prepared by the company's accountantR&D supplementary return within 30 days after the income tax return due date

Can you use both?

A trans-Tasman group can use both, company by company. The Australian company claims for R&D it conducts in Australia, and the New Zealand company for R&D it conducts in New Zealand. Neither country lets the same spend cross freely: Australia needs an overseas finding for work done abroad, and New Zealand caps foreign expenditure at 10% of the claim. Work the Australian company does in Australia for its New Zealand affiliate can still be claimed in Australia if the s 355-220 conditions are met. Keep separate time records for each company's staff.

Australia and New Zealand both call their scheme the R&D Tax Incentive, and both reward systematic experimental work. The similarities mostly end there. The design of the benefit, the approval process and the calendar are different enough that a trans-Tasman company should plan the two claims separately.

Rate design: premium versus flat credit

New Zealand gives a 15% tax credit on eligible R&D expenditure, between NZ$50,000 and NZ$120 million a year; a company can apply to IRD for approval to exceed the cap. The credit is applied after imputation credits and before refundable credits, and unused credits can be carried forward if the company meets shareholder continuity.

Australia's offset is the company tax rate plus a premium. For a company with aggregated turnover under $20 million, it is the tax rate plus 18.5 percentage points, which is 43.5% for a base rate entity taxed at 25%. Because the offset replaces the ordinary deduction for the same spend, the gain over a normal deduction is the 18.5 point premium for a company that can use its deductions; a company with no tax to pay receives the whole refundable offset as cash. Larger companies get a lower two-tier premium.

Approval comes first in New Zealand

New Zealand asks for approval before the claim. Most claimants use general approval, which since 1 April 2025 is due by the last day of the third month after the end of the first income year: 30 June for a 31 March balance date. IRD says it cannot accept late applications. The alternative, criteria and methodologies approval, is due even earlier, six months before that year ends.

Australia has no pre-approval for an ordinary claim. The company registers its activities with AusIndustry within 10 months after the income year ends, and can choose to seek an advance finding if it wants certainty in advance. The first hard date therefore comes about seven months later in Australia than in New Zealand for a company whose year ends in the same month.

Refunds

Australia pays the refundable offset as cash to the extent it exceeds tax payable, for companies under $20 million aggregated turnover that are not controlled by exempt entities. New Zealand's refunds are narrower: since 2020-21 every claimant uses the broader refundability rules, under which a company in a tax loss position, or with surplus credits, can be refunded up to a cap based on labour-related costs.

Running both: an illustrative sequence

A hypothetical Auckland and Melbourne software group with 30 June balance dates might run its year like this:

  1. By 30 September: the New Zealand company files general approval for the year just ended.
  2. Through the year: both companies keep contemporaneous evidence of their own experiments, with time recorded by company.
  3. By 30 April: the Australian company registers with AusIndustry. Rand can draft that registration from GitHub, Jira, Linear and Notion records and Xero payroll for the team to review and an Expert Reviewer to finalise; the company declares and submits it.
  4. Each company's accountant then prepares its own country's return and R&D schedule or supplementary return.

If the Melbourne company relies on Auckland engineers for part of an Australian experiment, it must apply for an overseas finding before the end of the first income year in which the overseas work is done, and must hold the positive finding before it claims the offset on that spend. See also overseas contractors and the R&D Tax Incentive calculator.

Frequently asked questions

Which country's incentive is worth more per dollar?
It depends on the company's tax position. New Zealand's credit is 15% of eligible spend whatever the tax rate. Australia's offset is the tax rate plus a premium, and it replaces the ordinary deduction, so for a company that can use its deductions the gain over a deduction is the premium. A company with turnover under $20 million and no tax to pay receives the refundable offset as cash. Price both for your own figures.
Our NZ company missed general approval. Can it still claim?
IRD says it cannot accept late general approval applications. Australia's system has no pre-approval step for ordinary claims, but the 10-month registration deadline has only limited extensions.
Can the Australian company pay the NZ team and claim the cost here?
Only if it holds a positive overseas finding for that work, and one of the conditions is that the activity cannot be conducted in Australia for an allowable reason, such as expertise or a facility being unavailable here. Already having a team in Auckland is not one of them.
Does using an approved research provider work the same way in both?
Similar idea, different detail. In New Zealand it can make a company eligible below the NZ$50,000 minimum. In Australia, amounts paid to a registered research service provider that is not an associate still earn the offset when total spend is under the $20,000 minimum, as do Cooperative Research Centre contributions. In both, you still have to show the activities are eligible.

Sources

  1. Inland Revenue (NZ), Research and development tax incentive
  2. Inland Revenue (NZ), About research and development tax incentive credits
  3. Inland Revenue (NZ), Research and development tax incentive due dates
  4. Inland Revenue (NZ), Eligible expenditure
  5. business.gov.au, Overview of the R&D Tax Incentive
  6. business.gov.au, Check if you are eligible for the R&D Tax Incentive

The R&D Tax Incentive is a self-assessment program. This page is general information, not tax, legal or financial advice; eligibility depends on your circumstances and you should seek independent advice for them.