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Engagements › Aegean Crest Shipping › Local File

Local File

Assembled section by section for each entity that owes one. Each section shows what it rests on and where it stands. Content follows OECD Ch. V, Annexes I–II.

Assembled section by section; exports as final only when confirmed.

Aegean Crest Navigation Inc.Aegean Crest Navigation II Inc.Aegean Crest Chartering LtdAegean Crest Shipping One LtdAegean Crest Shipping Two Ltd

DRAFT — not signed off. 7 of 7 sections are not yet confirmed; an export now carries the draft mark. Export Draft On iPad: Print → Save as PDF for a readable copy. Export As Final — export as final once all 7 sections are confirmed, 7 to go

1. The local entity

Draft

Aegean Crest Navigation Inc. is taken to be a company resident in Cyprus by management and control, to be confirmed by the practice. 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.

Group: Aegean Crest Shipping. Entities in the group: Aegean Crest Navigation Inc. (CY); Aegean Crest Navigation II Inc. (CY); Aegean Crest Ship Management Ltd (CY); Aegean Crest Chartering Ltd (CY); Aegean Crest Agencies Ltd (GB); Aegean Crest Holdings Corp. (MH); Aegean Crest Shipping One Ltd (CY); Aegean Crest Shipping Two Ltd (CY); Aegean Crest Shipping Three Inc. (CY); Aegean Crest Shipping Four Inc. (LR).

Documentation duty: services of €2,210,000 exceeds the €1,000,000 threshold the Tax Department publishes; financing, by its maximum principal, of €33,500,000 exceeds the €5,000,000 threshold the Tax Department publishes.

Sources: ITL s.2; ITL s.33(7)–(8); Tax Dept FAQ Q52; Tax Dept FAQ Q9–10; OECD Ch. V, Annexes I–II. Rests on: Obligations: Aegean Crest Navigation Inc. (draft).

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Rests on, not yet confirmed: Obligations: Aegean Crest Navigation Inc.

Next: 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.

HashContent hash db6ceeeb8265 · a change to it reopens every sign-off

2.1 Loan to the sister owner for a vessel purchase

Draft

Loan to the sister owner for a vessel purchase: Aegean Crest Navigation Inc. to Aegean Crest Navigation II Inc., interest €325,000 in the year on a maximum principal of €6,500,000.

Method: Interest at 5%, set by the group; never tested. Tested party: Aegean Crest Navigation Inc.

Circular 6/2023 safe harbour: not available: the category is over the threshold.

No written agreement on file.

Risk allocation: Lender bears the credit risk of the borrower.

Sources: OECD 1.36; Tax Dept FAQ Q31. Rests on: Financing: Loan to the sister owner for a vessel purchase (draft).

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ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Financing: Loan to the sister owner for a vessel purchase.

Next: 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.

HashContent hash 25f63bf1d111 · a change to it reopens every sign-off

2.2 Port agency services in the United Kingdom

Draft

Port agency services in the United Kingdom: Aegean Crest Agencies Ltd to Aegean Crest Navigation Inc., €410,000 in the year.

Method: Cost plus 5%. Tested party: Aegean Crest Agencies Ltd.

No benchmarking study in Cyprus: the tested party is outside Cyprus.

No written agreement on file.

Risk allocation: Owner bears the trading risk.

Sources: OECD 1.36.

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ReviewedVerifiedConfirmed

Next: 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.

HashContent hash 5730e0c3a9f3 · a change to it reopens every sign-off

2.3 Newbuilding loan to Shipping Two

Draft

Newbuilding loan to Shipping Two: Aegean Crest Navigation Inc. to Aegean Crest Shipping Two Ltd, interest €405,000 in the year on a maximum principal of €9,000,000.

Method: Interest at 4.5%, set by the group; never tested. Tested party: Aegean Crest Navigation Inc.

Circular 6/2023 safe harbour: not available: the category is over the threshold.

No written agreement on file.

Risk allocation: Lender bears the credit risk of the borrower; the vessel is mortgaged to the bank, not to the lender.

Sources: OECD 1.36; Tax Dept FAQ Q31. Rests on: Financing: Newbuilding loan to Shipping Two (draft).

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ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Financing: Newbuilding loan to Shipping Two.

Next: 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.

HashContent hash fc75d5dbb7f4 · a change to it reopens every sign-off

2.4 Guarantee of Shipping One's bank loan

Draft

Guarantee of Shipping One's bank loan: Aegean Crest Navigation Inc. to Aegean Crest Shipping One Ltd, no fee charged, on a maximum guaranteed amount of €18,000,000.

Method: No guarantee fee charged; no written agreement. Tested party: Aegean Crest Navigation Inc.

A guarantee: no safe harbour rate applies.

No written agreement on file.

Risk allocation: Guarantor bears the risk of the single-ship company defaulting.

Sources: OECD 1.36; OECD 10.161–10.177; Tax Dept FAQ Q5. Rests on: Financing: Guarantee of Shipping One's bank loan (draft).

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ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Financing: Guarantee of Shipping One's bank loan.

Next: 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.

HashContent hash 92f88b69120d · a change to it reopens every sign-off

2.5 Bareboat charter of m/v Aegean Wind from Liberia

Draft

Bareboat charter of m/v Aegean Wind from Liberia: Aegean Crest Shipping Four Inc. to Aegean Crest Navigation Inc., €1,800,000 in the year.

Method: Daily bareboat hire set by the group. Tested party: Aegean Crest Navigation Inc.

No written agreement on file.

Risk allocation: The charterer bears the operating and market risk; the owner bears the asset risk.

Sources: OECD 1.36. Rests on: Benchmarking: Bareboat charter of m/v Aegean Wind from Liberia (draft).

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ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Benchmarking: Bareboat charter of m/v Aegean Wind from Liberia.

Next: 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.

HashContent hash 9e41065213b0 · a change to it reopens every sign-off

3. Financial information

Draft

Financial information used in the analysis: Management accounts 2025, Aegean Crest companies (SHA-256 eaabf9be89019375…).

Loan to the sister owner for a vessel purchase: maximum principal €6,500,000; rate 5.00%; tenor not on file; interest in the year €325,000.

Newbuilding loan to Shipping Two: maximum principal €9,000,000; rate 4.50%; tenor not on file; interest in the year €405,000.

Guarantee of Shipping One's bank loan: maximum guaranteed amount €18,000,000; no fee charged; tenor not on file.

Sources: OECD Ch. V, Annexes I–II; Tax Dept FAQ Q9–10.

Sign-Off

ReviewedVerifiedConfirmed

Next: 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.

HashContent hash a15ff8314690 · a change to it reopens every sign-off