# Local File: Aegean Crest Navigation II Inc.
Financial year 2025. Prepared with tp.alp for Aegean Crest Shipping.

> **DRAFT — NOT SIGNED OFF.** 3 of 3 sections are not confirmed. Not for filing.

## 1. The local entity
Aegean Crest Navigation II 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 two Supramax vessels; 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: financing, by its maximum principal, of €6,500,000 exceeds the €5,000,000 threshold the Tax Department publishes.

_Sources: Income Tax Law 118(I)/2002, as amended by 244(I)/2025, section 2, "resident in the Republic", (β)(i)–(ii); Law 244(I)/2025 sections 2 and 25; Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022, section 33(7)–(8); Tax Department, Frequently Asked Questions about Transfer Pricing, question 52; Tax Department, Frequently Asked Questions about Transfer Pricing, questions 3, 9 and 10; OECD Transfer Pricing Guidelines 2022, Chapter V, Annex I and Annex II_
_Status: draft. Content hash 91e8a4dce324ada1b4e5e42477d089c589c02084077384cf0de3a0d1e61ee0db._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 2.1 Loan to the sister owner for a vessel purchase
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 Transfer Pricing Guidelines 2022, paragraph 1.36; Tax Department, Frequently Asked Questions about Transfer Pricing, questions 13, 31 and 42_
_Status: draft. Content hash 25f63bf1d111274e874a13e6e3f3153071d37c20e95e86e648403973cd2f4b57._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 3. Financial information
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.

_Sources: OECD Transfer Pricing Guidelines 2022, Chapter V, Annex I and Annex II; Tax Department, Frequently Asked Questions about Transfer Pricing, questions 3, 9 and 10_
_Status: draft. Content hash 1ab125e16e25b916631d38d9b564e3ba7e849fbca6229ac450f0509ae6247281._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet