Engagements › Aegean Crest Shipping › Financing
Financing
The interest charged on each intra-group loan against the practice's yield analysis, with the working shown, and against the Tax Department's safe harbours where they apply.
Loans against the yield analysis and the Tax Department's safe harbours.
Interest-free shareholder loan from the parent
Aegean Crest Holdings Corp. lends to Aegean Crest Navigation Inc.
| Working | Value | Source |
|---|---|---|
| Maximum principal | €14,000,000 | Balance sheet of Navigation Inc., maximum in the year (invented) |
| Rate charged | — | |
| Term | — | |
| Interest in the year | €0 | Management accounts 2025, Aegean Crest companies |
No independent yield analysis is on file for this loan: it is tested against the safe harbour below, where one applies.
Tax Department safe harbours Circular 6/2023
An interest-free balance: left out for the company that owes it for 2022–2026 Tax Dept FAQ Q25. For the lender it counts; whether arm's length interest is to be imputed is for the practice — to be confirmed by the practice.
Sign-Off
ReviewedVerifiedConfirmedNext: Reviewed, by a team member. Choose a person under View As to sign.
Evidence still outstanding: Accounts for 2022, 2023 and 2024 for every Cyprus company, due 12 Nov 2026 — in 5 days.
Evidence still outstanding: Board minutes showing management and control in Limassol, due 17 Nov 2026 — in 10 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
Hash
Content hash3a9267389c94 · a change to it reopens every sign-offLoan to the sister owner for a vessel purchase
Aegean Crest Navigation Inc. lends to Aegean Crest Navigation II Inc.
| Working | Value | Source |
|---|---|---|
| Maximum principal | €6,500,000 | Loan note, maximum in the year (invented) |
| Rate charged | 5.00% | Loan note: 5% a year (invented) |
| Term | — | |
| Interest in the year | €325,000 | Management accounts 2025, Aegean Crest companies |
No independent yield analysis is on file for this loan: it is tested against the safe harbour below, where one applies.
Tax Department safe harbours Circular 6/2023
Not available to Aegean Crest Navigation Inc.: the safe harbour rates apply only where its financial transactions stay under the published threshold, measured by the maximum principal — here financing €33,500,000 (Tax Dept FAQ Q31, Tax Dept FAQ Q9–10).
For comparison only, had it applied — Δ.2, lending from own funds Circular 6/2023 ¶18: the CY 10-year government bond yield for December 2024 2.81% plus 3.50% = 6.31%, against 5.00% charged — 1.31 points short of the minimum. Source: ECB, IRS/M.CY.L.L40.CI.0000.EUR.N.Z — a monthly average standing in for the yield the Tax Department publishes for the notional interest deduction at 31 December (Tax Dept FAQ Q26; Circular 6/2023 ¶21) — to be confirmed by the practice.
≈ €85,150 a year below the Δ.2 rate, for comparison only — the safe harbour is not available above the threshold (€6,500,000 × 1.31 points).
Sign-Off
ReviewedVerifiedConfirmedNext: Reviewed, by a team member. Choose a person under View As to sign.
Evidence still outstanding: Accounts for 2022, 2023 and 2024 for every Cyprus company, due 12 Nov 2026 — in 5 days.
Evidence still outstanding: Board minutes showing management and control in Limassol, due 17 Nov 2026 — in 10 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
Hash
Content hash1442e9ff6f6e · a change to it reopens every sign-offNewbuilding loan to Shipping Two
Aegean Crest Navigation Inc. lends to Aegean Crest Shipping Two Ltd.
| Working | Value | Source |
|---|---|---|
| Maximum principal | €9,000,000 | Loan note and shipyard instalments, maximum in the year (invented) |
| Rate charged | 4.50% | Loan note: 4.5% a year (invented) |
| Term | — | |
| Interest in the year | €405,000 | Management accounts 2025, Aegean Crest companies |
No independent yield analysis is on file for this loan: it is tested against the safe harbour below, where one applies.
Tax Department safe harbours Circular 6/2023
Not available to Aegean Crest Navigation Inc.: the safe harbour rates apply only where its financial transactions stay under the published threshold, measured by the maximum principal — here financing €33,500,000 (Tax Dept FAQ Q31, Tax Dept FAQ Q9–10).
For comparison only, had it applied — Δ.2, lending from own funds Circular 6/2023 ¶18: the CY 10-year government bond yield for December 2024 2.81% plus 3.50% = 6.31%, against 4.50% charged — 1.81 points short of the minimum. Source: ECB, IRS/M.CY.L.L40.CI.0000.EUR.N.Z — a monthly average standing in for the yield the Tax Department publishes for the notional interest deduction at 31 December (Tax Dept FAQ Q26; Circular 6/2023 ¶21) — to be confirmed by the practice.
≈ €162,900 a year below the Δ.2 rate, for comparison only — the safe harbour is not available above the threshold (€9,000,000 × 1.81 points).
Sign-Off
ReviewedVerifiedConfirmedNext: Reviewed, by a team member. Choose a person under View As to sign.
Evidence still outstanding: Accounts for 2022, 2023 and 2024 for every Cyprus company, due 12 Nov 2026 — in 5 days.
Evidence still outstanding: Board minutes showing management and control in Limassol, due 17 Nov 2026 — in 10 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
Hash
Content hash109a3c33d2a6 · a change to it reopens every sign-offGuarantee of Shipping One's bank loan
Aegean Crest Navigation Inc. guarantees a bank loan of Aegean Crest Shipping One Ltd.
| Working | Value | Source |
|---|---|---|
| Guaranteed amount | €18,000,000 | Bank facility letter for m/v Aegean Dawn: guaranteed amount (invented) |
| Guarantee fee rate | — | None charged |
| Term | — | |
| Fee charged in the year | €0 | Management accounts 2025, Aegean Crest companies |
Tax Department safe harbours Circular 6/2023
A guarantee, not a loan: no safe harbour rate applies. The benefit of group membership alone — implicit support — is passive association, for which no fee is payable; where the guarantee adds nothing beyond it, no fee is due. Where it adds something, the yield approach sets the maximum fee: the interest rate without the guarantee but with implicit support, less the rate with it OECD 10.161–10.177. Which applies here is a judgement for the practice on the facts. It counts as a financial transaction Tax Dept FAQ Q5.
Sign-Off
ReviewedVerifiedConfirmedNext: Reviewed, by a team member. Choose a person under View As to sign.
Evidence still outstanding: Accounts for 2022, 2023 and 2024 for every Cyprus company, due 12 Nov 2026 — in 5 days.
Evidence still outstanding: Board minutes showing management and control in Limassol, due 17 Nov 2026 — in 10 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
Hash
Content hash8e8c4da338d8 · a change to it reopens every sign-offSale proceeds left with Navigation Inc.
Aegean Crest Shipping Three Inc. lends to Aegean Crest Navigation Inc.
| Working | Value | Source |
|---|---|---|
| Maximum principal | €2,100,000 | Sale proceeds of m/v Aegean Star left with Navigation Inc., maximum in the year (invented) |
| Rate charged | — | |
| Term | — | |
| Interest in the year | €0 | Management accounts 2025, Aegean Crest companies |
No independent yield analysis is on file for this loan: it is tested against the safe harbour below, where one applies.
Tax Department safe harbours Circular 6/2023
An interest-free balance: left out for the company that owes it for 2022–2026 Tax Dept FAQ Q25. For the lender it counts; whether arm's length interest is to be imputed is for the practice — to be confirmed by the practice.
Sign-Off
ReviewedVerifiedConfirmedNext: Reviewed, by a team member. Choose a person under View As to sign.
Evidence still outstanding: Accounts for 2022, 2023 and 2024 for every Cyprus company, due 12 Nov 2026 — in 5 days.
Evidence still outstanding: Board minutes showing management and control in Limassol, due 17 Nov 2026 — in 10 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
Hash
Content hash7d42a02946a2 · a change to it reopens every sign-off