Engagements › Aegean Crest Shipping › Overview
Aegean Crest Shipping
A Marshall Islands shipping group run from Limassol, under tonnage tax, that has never done any transfer pricing: four tax years to catch up, a chartering desk under income tax, and loans between tonnage tax owners. Financial year 2025.
Team: Niki Papas, team member · Sofia Hart, team member · Andreas Lane, manager · Jane Doe, partner
At A Glance
0 of 46 items confirmedThe Group
Parent: Aegean Crest Holdings Corp. (MH). Entities in CY, GB, MH, LR.
- Aegean Crest Navigation Inc. — tonnage tax · incorporated in the Marshall Islands · Local File (the guarantee's measure to be confirmed) · Summary Table
- Aegean Crest Navigation II Inc. — tonnage tax · incorporated in the Marshall Islands · Local File (a point to be confirmed by the practice) · Summary Table
- Aegean Crest Ship Management Ltd — tonnage tax · nothing to report: a nil table to be confirmed by the practice
- Aegean Crest Chartering Ltd — income tax · Local File · Summary Table
- Aegean Crest Shipping One Ltd — tonnage tax · Local File (the guarantee's measure to be confirmed) · Summary Table
- Aegean Crest Shipping Two Ltd — tonnage tax · Local File (a point to be confirmed by the practice) · Summary Table
- Aegean Crest Shipping Three Inc. — tonnage tax · incorporated in the Marshall Islands · Summary Table
The Year, 2025
- Services: €12,195,000 (7 transactions, before exclusions)
- Financing: €49,600,000 (5 transactions, by maximum principal, before exclusions)
From The Partner
- A dry bulk owner, incorporated in the Marshall Islands, run from Limassol: tax resident in Cyprus if management and control is there — the board minutes will tell.
- Eight vessels: three owned by Navigation Inc., two Supramaxes by Navigation II, and three in single-ship companies bareboat-chartered to Navigation Inc. — two Cyprus SPVs and a Liberian SPV run from Monaco that is not Cyprus resident at all; a fourth SPV, Marshall Islands, sold its ship in March 2025 and is dormant.
- Under tonnage tax, so most flows fall away; the chartering desk, the loans between owners, the no-fee guarantee and the Liberian charter do not, or not clearly.
- Nothing has ever been documented: four tax years to catch up — 2022 and 2023 are late, 2024 falls due on 30 November 2026, 2025 next spring.
Points To Know
To Act On
- Never documented: tax years 2022 to 2025 to catch up.
- Loan to the sister owner for a vessel purchase: whether interest between two tonnage tax owners is qualifying income — to be confirmed by the practice.
- Port agency services in the United Kingdom: whether the agency fee falls outside the table by analogy to FAQ Q23 (Q23 is about a Party B under Cyprus income tax; the UK agency is not) — to be confirmed by the practice.
- Bareboat charter of m/v Aegean Dawn: whether bareboat chartering out is a qualifying shipping activity of the owner under the Merchant Shipping law — to be confirmed by the practice.
- Bareboat charter of m/v Aegean Spirit: whether bareboat chartering out is a qualifying shipping activity of the owner under the Merchant Shipping law — to be confirmed by the practice.
- Newbuilding loan to Shipping Two: whether interest between two tonnage tax owners is qualifying income — to be confirmed by the practice.
- Guarantee of Shipping One's bank loan: no fee charged and no agreement on file.
- Bareboat charter of m/v Aegean Wind from Liberia: whether a tonnage tax owner's charter from a related company outside the Cyprus tonnage tax system counts — to be confirmed by the practice.
- In scope for Pillar Two since 2024: the top-up tax information return for 2025 is due 31 Mar 2027. The 2024 filings, due earlier, carry no fines, interest or charges if made by 30 November 2026.
To Watch
- Ship management of the bulk carriers: no written agreement on file.
- Ship management of the Supramaxes: no written agreement on file.
- Chartering commissions: no written agreement on file.
- Interest-free shareholder loan from the parent: no written agreement on file.
- Loan to the sister owner for a vessel purchase: no written agreement on file.
- Port agency services in the United Kingdom: no written agreement on file.
- Bareboat charter of m/v Aegean Dawn: no written agreement on file.
- Bareboat charter of m/v Aegean Spirit: no written agreement on file.
- Newbuilding loan to Shipping Two: no written agreement on file.
- Sale proceeds left with Navigation Inc.: no written agreement on file.
- Bareboat charter of m/v Aegean Wind from Liberia: no written agreement on file.
- Country-by-country reporting for 2025: the group is over €750,000,000 for 2024; each Cyprus company notifies by 31 Dec 2025 — past; whether it was made is to be established.
- Country-by-country reporting for 2026: the group is over €750,000,000 for 2025; each Cyprus company notifies by 31 Dec 2026.
- 4 rules this engagement relies on are still to be confirmed by the practice.
Left Out, Settled · 7 points
- Ship management of the bulk carriers: left out for Navigation Inc. and Ship Management Ltd — both parties are under tonnage tax: qualifying ship management between a qualifying manager and a qualifying owner.
- Chartering commissions: left out for Navigation Inc. — the owner is under tonnage tax and the chartering desk is not: only the chartering desk's income-taxed side counts (FAQ question 23).
- Interest-free shareholder loan from the parent: left out for Navigation Inc. — an interest-free payable: left out for the company that owes it (2022–2026).
- Bareboat charter of m/v Aegean Dawn: left out for Navigation Inc. and Shipping One Ltd — both parties are under tonnage tax: bareboat chartering between two qualifying owners.
- Bareboat charter of m/v Aegean Spirit: left out for Navigation Inc. and Shipping Two Ltd — both parties are under tonnage tax: bareboat chartering between two qualifying owners.
- Sale proceeds left with Navigation Inc.: left out for Navigation Inc. — an interest-free payable: left out for the company that owes it (2022–2026).
- Ship management of the Supramaxes: left out for Navigation II Inc. and Ship Management Ltd — both parties are under tonnage tax: qualifying ship management between a qualifying manager and a qualifying owner.
The group, its transactions, and where the sign-offs stand.
Where The Sign-Offs Stand
| What | Items | Reviewed | Verified | Confirmed |
|---|---|---|---|---|
| Obligations | 7 | 0 | 0 | 0 |
| Benchmarking | 2 | 0 | 0 | 0 |
| Financing | 5 | 0 | 0 | 0 |
| Draft Agreements | 12 | 0 | 0 | 0 |
| Pillar Two | 1 | 0 | 0 | 0 |
| Local File Sections | 19 | 0 | 0 | 0 |
| All Items | 46 | 0 | 0 | 0 |
The Group
| Entity | Country | Activity | Look It Up |
|---|---|---|---|
| Aegean Crest Navigation Inc. | CY | Incorporated in the Marshall Islands; if managed and controlled from Limassol (board minutes requested), tax resident in Cyprus. Owns three dry bulk carriers and operates three more bareboat-chartered in from the single-ship companies; a qualifying owner under tonnage tax | Registries and LEI |
| Aegean Crest Navigation II Inc. | CY | Incorporated in the Marshall Islands; if managed and controlled from Limassol (board minutes requested), tax resident in Cyprus. Owns two Supramax vessels; a qualifying owner under tonnage tax | Registries and LEI |
| Aegean Crest Ship Management Ltd | CY | Technical management of the group's eight vessels: the five owned by the two Navigation companies and the three bareboat-chartered in by Navigation Inc.; a qualifying ship manager under tonnage tax | Registries and LEI |
| Aegean Crest Chartering Ltd | CY | Chartering desk: finds cargoes and fixes the vessels for a commission; not a qualifying activity, so under income tax | Registries and LEI |
| Aegean Crest Agencies Ltd | GB | Port agency in the United Kingdom | Registries and LEI |
| Aegean Crest Holdings Corp. | MH | Ultimate parent of the group, incorporated and managed outside Cyprus; not a Cyprus resident | Registries and LEI |
| Aegean Crest Shipping One Ltd | CY | Single-ship company: owns m/v Aegean Dawn and bareboat-charters her to Navigation Inc.; a qualifying owner under tonnage tax; its bank loan is guaranteed by Navigation Inc. | Registries and LEI |
| Aegean Crest Shipping Two Ltd | CY | Single-ship company: owns m/v Aegean Spirit, delivered in 2025, funded by Navigation Inc. and bareboat-chartered to her; a qualifying owner under tonnage tax | Registries and LEI |
| Aegean Crest Shipping Three Inc. | CY | Incorporated in the Marshall Islands; if managed and controlled from Limassol (board minutes requested), tax resident in Cyprus. Single-ship company and a qualifying owner under tonnage tax until the sale: sold m/v Aegean Star in March 2025 and is now dormant; the sale proceeds were left with Navigation Inc. | Registries and LEI |
| Aegean Crest Shipping Four Inc. | LR | Incorporated in Liberia and managed from Monaco, so not a Cyprus resident; owns m/v Aegean Wind, bareboat-chartered to Navigation Inc. | Registries and LEI |
Controlled Transactions, Financial Year 2025
| Transaction | From | To | Category | Amount | Method |
|---|---|---|---|---|---|
| Ship management of the bulk carriers | Aegean Crest Ship Management Ltd | Aegean Crest Navigation Inc. | Services | €1,900,000 | Cost plus, ship management |
| Ship management of the Supramaxes | Aegean Crest Ship Management Ltd | Aegean Crest Navigation II Inc. | Services | €1,350,000 | Cost plus, ship management |
| Chartering commissions | Aegean Crest Chartering Ltd | Aegean Crest Navigation Inc. | Services | €1,235,000 | Comparable uncontrolled price: the commission rate against market address commission and brokerage rates |
| Interest-free shareholder loan from the parent | Aegean Crest Holdings Corp. | Aegean Crest Navigation Inc. | Financing | €0 interest · principal €14,000,000 | None charged: an interest-free balance |
| Loan to the sister owner for a vessel purchase | Aegean Crest Navigation Inc. | Aegean Crest Navigation II Inc. | Financing | €325,000 interest · principal €6,500,000 | Interest at 5%, set by the group; never tested |
| Port agency services in the United Kingdom | Aegean Crest Agencies Ltd | Aegean Crest Navigation Inc. | Services | €410,000 | Cost plus 5% |
| Bareboat charter of m/v Aegean Dawn | Aegean Crest Shipping One Ltd | Aegean Crest Navigation Inc. | Services | €2,900,000 | Daily bareboat hire set by the group |
| Bareboat charter of m/v Aegean Spirit | Aegean Crest Shipping Two Ltd | Aegean Crest Navigation Inc. | Services | €2,600,000 | Daily bareboat hire set by the group |
| Newbuilding loan to Shipping Two | Aegean Crest Navigation Inc. | Aegean Crest Shipping Two Ltd | Financing | €405,000 interest · principal €9,000,000 | Interest at 4.5%, set by the group; never tested |
| Guarantee of Shipping One's bank loan | Aegean Crest Navigation Inc. | Aegean Crest Shipping One Ltd | Financing | €0 fee · guaranteed amount €18,000,000 | No guarantee fee charged; no written agreement |
| Sale proceeds left with Navigation Inc. | Aegean Crest Shipping Three Inc. | Aegean Crest Navigation Inc. | Financing | €0 interest · principal €2,100,000 | None charged: an interest-free balance |
| Bareboat charter of m/v Aegean Wind from Liberia | Aegean Crest Shipping Four Inc. | Aegean Crest Navigation Inc. | Services | €1,800,000 | Daily bareboat hire set by the group |