Exhibit 8.1
List of Subsidiaries
As of June 30, 2018
| Subsidiaries of the Registrant:
Name | Place of Incorporation | |
| Agria Group Limited (formerly known as Aero-Biotech Group Limited) | British Virgin Islands (“BVI”) | |
| China Victory International Holdings Limited | Hong Kong | |
| Aero Biotech Science & Technology Co., Ltd. | People’s Republic of China (“PRC”) | |
| Agria Holdings (Shenzhen) Co., Ltd. (formerly known as Agria Brother Biotech (Shenzhen) Co., Ltd.) | PRC | |
| Agria Biotech Overseas Limited | Hong Kong | |
| Agria Asia International Limited | Hong Kong | |
| Hiltex Investment Limited | BVI | |
| Golden Hero International Co., Ltd. | Hong Kong | |
| Agria Asia Investments Ltd. (formerly known as Southrich Limited) | BVI | |
| Agria (Singapore) Pte. Ltd | Singapore | |
| Agria Corporation (New Zealand) Ltd | New Zealand | |
| Agria NZ Finance Limited | New Zealand | |
| PGG Wrightson Limited | New Zealand | |
| PGW Wrightson Seeds Holdings Limited | New Zealand | |
| PGW Rural Capital Limited | New Zealand | |
| PGG Wrightson Employee Benefits Plan Trustee Limited | New Zealand | |
| PGG Wrightson Real Estate Limited | New Zealand | |
| Agriculture New Zealand Limited | New Zealand | |
| PGG Wrightson Trustee Limited | New Zealand | |
| AgriServices South America Limited | New Zealand | |
| PGW AgriServices Australia Pty Limited | Australia | |
| PGG Wrightson Investments Limited | New Zealand | |
| Bloch & Behrens Wool (NZ) Limited | New Zealand | |
| NZ Agritrade Limited (formerly known as Agri-feeds Limited) | New Zealand | |
| Ag Property Holdings Limited | New Zealand | |
| PGG Wrightson Seeds New Zealand Limited | New Zealand | |
| PGG Wrightson Seeds South America Holdings Limited | New Zealand | |
| PGG Wrightson Seeds Australia Holdings Pty Limited | Australia | |
| PGG Wrightson Seeds Limited | New Zealand | |
| PGG Wrightson Consortia Research Limited | New Zealand |
| Subsidiaries of the Registrant:
Name | Place of Incorporation | |
| Grasslands Innovation Limited | New Zealand | |
| Agricom Limited | New Zealand | |
| Wrightson Seeds Limited | New Zealand | |
| PGG Wrightson Employee Benefits Plan Limited | New Zealand | |
| PGG Wrightson Seeds (Australia) Pty Limited | Australia | |
| PGW AgriTech South America S.A. | Uruguay | |
| Wrightson Pas S.A. | Uruguay | |
| Juzay S.A. | Uruguay | |
| Agrosan S.A. | Uruguay | |
| PGW Wrightson Seeds Argentina S.A. (previously Alfalfares S.R.L.) | Argentina | |
| PGW Sementes Ltda (previously NZ Ruralco Participacoes Ltda) | Brazil | |
| Hunker S.A. (t/a Rural Centre) | Uruguay | |
| Lanelle S.A. (t/a Riegoriental) | Uruguay | |
| Afinlux S.A. (t/a Romualdo Rodriguez) | Uruguay | |
| Kroslyn S.A. Limited | Uruguay | |
| Escritorio Romualdo Rodriguez Ltda | Uruguay |
Consolidated Structured Entities of the Registrant and their Subsidiaries:
| Name | Place of Incorporation | |
| Shenzhen Zhongguan Agriculture Group Co., Ltd. (formerly known as Shenzhen Guanli Agricultural Technology Co., Ltd.) | PRC | |
| Agria NKY Seeds Co., Ltd. (formerly known as Beijing NKY Seeding Development Co., Ltd.) | PRC | |
| Shenzhen NKY Seeds Co., Ltd. (formerly known as Shenzhen Agria Agricultural Co., Ltd.) | PRC | |
| Shenzhen Zhongguan Forage Co., Ltd. (formerly known as Shenzhen Zhongyuan Agriculture Co., Ltd.) | PRC | |
| Tianjin Beiao Seeds Technology Development Co., Ltd. | PRC | |
| Wuwei NKY Seeds Co., Ltd. | PRC | |
| Shanxi Jufeng Seeds Co., Ltd. Zhuhai NKY Seeds Co., Ltd. | PRC PRC | |
| Zhuhai Jintain Agriculture Development Co., Ltd. | PRC |