Engagements › Aegean Crest Shipping › Catch-Up Plan
Catch-Up Plan
Aegean Crest Shipping has never documented its transfer pricing. The duty runs from tax year 2022 (L.101(I)/2022). This is what each year owed, what is missing, what it can cost, and the order to put it right.
Never documented: each year since the duty began, and the order to fix it.
Not counted: Aegean Crest Ship Management Ltd — every controlled transaction is left out, so there is nothing to report; the return still answers YES to its controlled transactions question (Tax Dept FAQ Q51). Whether a nil table is filed, and so whether a fine could arise, is to be confirmed by the practice.
| Tax Year | Return And Summary Table Due | Status | Local File | Source |
|---|---|---|---|---|
| 2022 | 28 Feb 2025 no charges on the return if filed by 31 May 2025 | Not filed — late | To be established from the 2022 accounts (requested) | Tax Dept FAQ Q15 |
| 2023 | 31 Mar 2026 no charges on the return if filed by 30 Apr 2026 | Not filed — late | To be established from the 2023 accounts (requested) | K.D.P. 358/2025 |
| 2024 | 30 Nov 2026 | Due in 23 days | To be established from the 2024 accounts (requested) | K.D.P. 359/2025 |
| 2025 | 31 Mar 2027 to be confirmed by the practice | Due | Required for Navigation Inc., Navigation II Inc., Chartering Ltd, Shipping One Ltd, Shipping Two Ltd, on 2025's figures | ACT, to 2025 · to be confirmed by the practice |
The Order Of Work
Settle who is in Cyprus.
The Marshall Islands companies are Cyprus residents only if their control and management are exercised in Cyprus (ITL s.2); whether that is Limassol, in fact, is for the board minutes, which are requested — to be confirmed by the practice (the rule is read; the fact is not yet established). That decides which companies owe anything at all (ITL s.33(7)–(8)).
Map the connected persons and transactions, year by year.
The 25% test (ITL s.33(3)); then, for each year, what is left out — tonnage tax both sides (Tax Dept FAQ Q22–24), the interest-free balance for the payer (Tax Dept FAQ Q25) — and what counts, including the chartering desk's side and the loan between the owners, which is to be confirmed by the practice (whether interest between two tonnage tax owners is qualifying income).
File the missing Summary Tables, oldest first — and 2024's on time.
One per Cyprus company per year, whatever the value (ITL s.33(10)). For 2022 the penalty-free window closed on 31 May 2025 (Tax Dept FAQ Q15). For 2023, no monetary charges on the return if filed by 30 April 2026 (K.D.P. 358/2025); whether the €500 Summary Table fine was also waived is to be confirmed by the practice (the announcement waives monetary charges; the fine is an administrative fine under ACT s.50Ζ) (The 2023 waiver and the fine · to be confirmed by the practice). Tax year 2024 is due 30 November 2026 (K.D.P. 359/2025): filed in time, it carries no fine at all.
Prepare the Local Files for the years over the threshold.
Each with its certified accountant's quality-assurance check, whose confirmation is uploaded with the Summary Table (ITL s.33(10)). Ready to produce within 60 days of a request (ITL s.33(11)).
Put 2026 on a footing.
Agreements for the chartering commissions and the loan, drafted from the policy (Agreements), the loans against the yield analysis (Financing): the safe harbour is not available above the financing threshold (Tax Dept FAQ Q31), and a year-end true-up before 31 December (True-Ups).
Advise the client on the approach to the Tax Department.
How and when to come forward is the partner's advice, not the tool's.