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

> **DRAFT — NOT SIGNED OFF.** 7 of 7 sections are not confirmed. Not for filing.

## 1. The local entity
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: 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 db6ceeeb82652aab28627e29ce4fee9c3d40b25c4656b2f7e1fdf284d0177363._
- 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

## 2.2 Port agency services in the United Kingdom
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 Transfer Pricing Guidelines 2022, paragraph 1.36_
_Status: draft. Content hash 5730e0c3a9f36c5adea3e1e0d2c5f30b84adf77891c521a1a53873d79678ffe1._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 2.3 Newbuilding loan to Shipping Two
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 Transfer Pricing Guidelines 2022, paragraph 1.36; Tax Department, Frequently Asked Questions about Transfer Pricing, questions 13, 31 and 42_
_Status: draft. Content hash fc75d5dbb7f40a67a48cfd52b7a2a91de5b938d43980383aa961f5c04a45c5a0._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 2.4 Guarantee of Shipping One's bank loan
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 Transfer Pricing Guidelines 2022, paragraph 1.36; OECD Transfer Pricing Guidelines 2022, paragraphs 10.161–10.177; Tax Department, Frequently Asked Questions about Transfer Pricing, question 5_
_Status: draft. Content hash 92f88b69120d4d2e672a29de32dce9507a72996e755f2dc0dad101fe469f364c._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 2.5 Bareboat charter of m/v Aegean Wind from Liberia
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 Transfer Pricing Guidelines 2022, paragraph 1.36_
_Status: draft. Content hash 9e41065213b0bb021672665311b74f92cf01e85baab5b0d10eceae8784a03359._
- 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.
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 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 a15ff8314690818ea628b7e160b81d8702a925dfe66aeedbf6206f2e1e2390d7._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet